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ABA Tax Section Comments on Assets-Over Partnership Mergers
This article discusses the ABA Tax Section submitted comments concerning the tax treatment of property distributions following partnership mergers.
IRS Releases Memorandum on Low-Income Housing Limited Partnerships
This article discusses the April 25, 20016 IRS memorandum, issued to its exempt organizations determination agents, explaining the criteria for processing exemption applications under Section 501(c)(3) or (c)(4) for ...
S Corporation Entitled to Interest on Overpayment at the Federal Short-Term Rate Plus 2%
This article discusses Garwood Irrigation Co., where the Tax Court addressed a situation in which an S corporation had overpaid the Section 1374 corporate-level ‘built-in gains tax‘ and was entitled to recover the overpayment ...
Public Comment Requested on Potential Changes to Certain Distributions Treated as Sales or Exchanges Under Section 751(b)
This article discusses the Treasury Department and IRS recent request for comments on the approaches discussed in Notice 2006-14, 2006-8 IRB 498, in determining a partner's share of hot assets and prescribing the tax ...
Tax Court Memorandum Decision Addresses Back-to-Back Loans
This article discusses Ruckriegel, where the Tax Court addressed (in a memorandum opinion) whether the owners of an S corporation could treat certain advances as loans by them to the S corporation and use those loans to ...
FAA Provides Guidance on Calculating the Amount of Gross Income Omitted for Purposes of Determining the Section
This article discusses the Field Attorney Advice (FAA) released on February 1, 2006, involving a taxpayer who purchased a tax avoidance scheme to divert and omit income on her Form 1040.
IRS Rules on Treatment of Parent Corporation's Payment to Partnership
This article discusses the result of Rev. Rul. 2006-11, 2006-12 IRB 635, which involved a common parent of an affiliated group of corporations and a partner in PRS subject to the 1982 TEFRA partnership procedures.