Topics

July 1, 2008

Court Reverses Broad-Based FICA Exclusion for Severance Payments

In March 2008, the Federal Circuit reversed a decision of the Court of Federal Claims that the qualification of payments as supplemental unemployment benefits under Sec. 3402 required the payments to be treated as nonwages for FICA tax purposes.

May 1, 2008

Final Regs. on Consolidated Group Liquidations

Final regulations effective January 15, 2008, explain how the members of a consolidated group succeed to tax items, or “attributes,” of a subsidiary corporation when two or more members of the group own stock in the subsidiary and the subsidiary is liquidated on a tax-free basis

January 1, 2008

FIN 48 Compliance: Disclosing Tax Positions in an Age of Uncertainty

FIN 48 presents new challenges for taxpayers, auditors, and tax advisers. The disclosures required by the interaction of FAS 109 and FIN 48 will result in greater public disclosure of tax planning techniques, including the strengths and weaknesses of those techniques.

January 1, 2008

Accounting Period Changes Affecting CFCs and Corporations Exiting a Consolidated Group

The IRS has modified the scope provision for corporations that exit a consolidated group and request consent to change their annual accounting periods.

October 1, 2007

Final Regulations on Dual Consolidated Losses: A Practical Guide (Part II)

This article discusses triggering events for dual consolidated losses and their consequences, as well as the transition rules from the 1992 to the 2007 regulations.

September 1, 2007

Final Regulations on Dual Consolidated Losses: A Practical Guide (Part I)

The 2007 dual consolidated loss regulations generally provide that a DCL of a dual-resident corporation or a separate unit of a U.S. corporation is not included in the computation of the taxable income of a consolidated group, unaffiliated DRC, or unaffiliated domestic owner.

July 1, 2007

Professional Corporations: To Be or Not to Be a Member of a Consolidated Group

Editor: Annette B. Smith, CPA Many independent professional medical and dental practices are incorporated under state law as professional corporations (PCs). Generally, these state laws require that PCs issue shares only to individuals who are duly licensed or otherwise legally authorized to render the same type of professional services as

June 1, 2007

Taxpayer-Favorable Letter Ruling on Consolidated Worthless Stock Deduction

Editor: Mary Van Leuven, J.D., LL.M. IRS Letter Ruling 200710004 breaks new ground in determining the character of a worthless stock deduction in a consolidated group. Due to the lack of direct authorities on point and the absence of clear statutory support for the ruling’s favorable conclusions, taxpayers might consider

June 1, 2007

Avoiding Late Returns When Corporations Are Acquired by a Consolidated Group

Editor: Mary Van Leuven, J.D., LL.M. Often, a corporation will not qualify as a member of a consolidated group for its entire tax year. This could occur because an event (a “change in status”) causes the corporation to become or cease to be a member of the consolidated group on