July 2013 - The Tax Adviser

Opportunity to Eliminate Certain Intercompany Gain

Totalization Agreements: Taking Exception to Social Security

Interplay of Withholding Obligations on Partnership’s Disposition of U.S. Real Property

Foreign Branch Incorporation: Interaction of OFL, Branch Loss Recapture Rules

Defining “Attributable to” Under Sec. 897(g)

LIFO Inventory Considerations When Making a C-to-S Conversion

Understanding the Principles of DASTM Accounting

Timing of Revenue Recognition for Retainages

Whether Incentives That Require Companies to Provide Jobs Should Be Treated As Nonshareholder Capital Contributions

Failing Subchapter C Requirements to Avoid Nonrecognition Treatment

ATRA Allows Taxpayers to Continue to Accelerate Certain AMT Credits

Final Regulations for Noncompensatory Partnership Options

Application of Sec. 704(c) to Divisions

Unresolved Issues Regarding Sec. 6603 Deposits

Questions on EINs in F Reorganizations Involving Disregarded Entities

Innocent-Spouse Defense Against Assessments on a Joint Return

CPAs and Comfort Letters: The New Chocolate

Sec. 336(e) Election Regulations Are Issued

Proposed Rules Address Minimum Value of Health Coverage for Premium Tax Credits

IRS Will Get Search Warrants When Seeking Taxpayer Emails

IRS Issues HSA Inflation Adjustments for 2014

Final Regs. Require EIN Holders to Update Information With IRS

Final Regs. Permanently Extend Period to Receive Disclosure Authorization

Entities With Less Than $50 Million in Assets Get New Schedule M-3 Filing Rules

The Collection Appeal Procedures and Collection Due Process Programs

Schedule UTP: Update on IRS Findings

Options for Compliance With Worker Classification Rules

Nine Factors That Determine Whether an Activity Is a Hobby

Loan Guarantees Were Prohibited Transactions That Disqualified IRAs

A Closer Look at the IRS’s Targeting of Tea Party and Other Groups for Review