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July 2019 - The Tax Adviser

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  2. July 2019
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TAX ACCOUNTING

The cost of deferred revenue

This article discusses the treatment of unearned revenue from a financial accounting and tax point of view and how unearned revenue can affect the seller and the buyer in an M&A transaction.

TAX CLINIC

CONSOLIDATED RETURNS

Consolidated return regs. provide special return due-date rules for short tax years

corporations & shareholders

Allocating previously taxed income in a Sec. 355 tax-free distribution

CFC worthless stock deductions after tax reform

exempt organizations

Tax reform’s impact on pension trusts and tax-exempt organizations in trust form

expenses & deductions

Determining what is a separate trade or business for Sec. 199A purposes

FOREIGN INCOME & TAXPAYERS

Restructuring with Sec. 987 QBUs? Watch for limitations under new Sec. 987 regs.

GROSS INCOME

Sec. 1341: What is the claim-of-right doctrine?

partners & partnerships

BBA audit regime affects buyers and sellers of partnership interests

TAX ACCOUNTING

Foreign corporations may not receive audit protection for accounting method changes

COLUMNS

NEWS NOTES

AICPA requests further guidance on QBI deduction

Traded player contracts and draft picks have zero value under safe harbor

IRS proposes regs. on withholding on transfers of partnership interests

IRS issues more proposed regs. on qualified opportunity funds

TAX PRACTICE & PROCEDURES

A preparer-client decision: Whether to rely on the Sec. 199A proposed or final regulations

IRS provides safe harbor for professional sports teams trading personnel contracts and draft picks

CASE STUDY

Using trusts to shift income to children

TAX TRENDS

Regulations take precedence over common law mailbox rule

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