February 2014 - The Tax Adviser

Current Developments for Straddle Transactions

District Court Considers Taxpayer’s Privilege and Work Product Doctrine Claims in IRS Summons Action

Cost Basis Denied Due to Failure to Meet the All-Events Test

Continuing Efforts to Amend the Multistate Tax Compact

Transfer-Pricing Documentation: Possible Relief Ahead for Small Multinational Companies

Bonus Deduction Timing: Finding the Correct Tax Year

Solving a Problem With Sec. 338 Purchase-Price Allocations

Sec. 382 Final Regs. for Small Shareholders

Hook Stock and Sec. 355: Did a Distribution Occur?

Cloud Computing and the Credit for Increasing Research Activities

Sec. 199 Contract Manufacturing Guidance May Encourage Taxpayers to Agree on Benefits and Burdens

Don’t Forget the Mandatory Application of Sec. 732(d)

New IDR Policy Means Stricter Deadlines, More Discussions

Faculty Internships: Connecting Tax Practice and Academia

Contributing Intangible Property to an LLC

Proposed Regs. Issued on Amortization of Startup Expenses by Terminating Partnerships

Midyear Changes to Employer Contributions to 401(k) Plans Allowed

In-Plan Rollovers to Roth Accounts

Final Regs. Permit Agents to Withhold FUTA for Home Care Service Recipients

3.8% Net Investment Income Tax Regulations

2014 Standard Mileage Rates Go Down

0.9% Medicare Surtax Final Regulations Issued

An Overview of AICPA and IRS Rules of Practice

Valuation-Misstatement Penalty Applies to Tax Shelter Transactions

Taxpayer Not Properly Accounting for Advance Payments

Taxpayer Did Not Have Fraudulent Intent

Earnout Restriction Causes Substantial Risk of Forfeiture