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July 2016 - The Tax Adviser

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  2. July 2016
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credits against tax

Practical Documentation of QRAs for the R&D Tax Credit

In the absence of records specifically created to document the research tax credit, taxpayers
often have to rely on estimates and an assortment of documents, interviews, and other evidence to substantiate expenditures that qualify for the research tax credits.

TAX CLINIC

CONSOLIDATED RETURNS

Sec. 108(i): Considerations for Electing Consolidated Groups

corporations & shareholders

Double and Triple Drops With Liquidations Clarified in Pair of Revenue Rulings

EMPLOYMENT TAXES

Worker Classification and the Evolving Service Delivery Model

exempt organizations

Supporting Organizations: A Road Map to the Recent Regulations

FOREIGN INCOME & TAXPAYERS

Issues Involving the Interplay of Subpart F Income Recapture Account and Sec. 956 Inclusion

partners & partnerships

Missing Partnership Merger Definition Raises Questions

Time to Adjust: Adding to the List of Partnership Revaluation Events

PRACTICE & PROCEDURES

Ratification May Fix Signature Problems

REAL ESTATE

PATH Act Modifies REIT Prohibited-Transaction Safe Harbors

SPECIAL INDUSTRIES

Changes to Elections by Small Captive Insurance Companies

STATE & LOCAL TAXES

Sales and Use Tax Audit Sampling

COLUMNS

NEWS NOTES

IRS Updates Automatic Accounting Change Procedures

Health Savings Account Limits for 2017 Are Issued

LB&I Announces Expanded Prefiling Agreement Program, Significant User Fee Increase

Temporary Regulations Prohibit Partners From Being Employees

Final Rules Permit Broader Range of Program-Related Investments

Material Adviser Penalty Rules Are Clarified

TAX PRACTICE & PROCEDURES

Navigating the Murky Waters of IRS Payment Agreements

Why the AICPA SSTSs and IRS Circular 230 Should Be Added to CPAs’ Lists of Favorite Resources

ITINs: The Rules Have Changed

DC CURRENTS

Tax Reform: Beyond Lowering Income Tax Rates

CASE STUDY

Valuing and Substantiating Charitable Contributions

TAX TRENDS

Nevada Must Treat California Agency Like a Nevada Agency in Damages Claim

Potential Expiration Is Not an Event

INDIVIDUALS

Current Developments in Taxation of Individuals: Part 1

This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.

Tax Clinic

Planning for domestication transactions

Planning for new charitable contribution limits

Effect of the new pro rata share rules

Determining when a debt instrument has zero basis

Structuring partnership mergers