August
2010
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BY
Suzi Graden, CPA
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Article
I am a CPA and a mom via adoption times two. I was baffled to read in the April 2010 article “Tax Treatment of Adoption Expenses” (page 44) that adoptive parents “may want to give more consideration to a specialneeds child or international adoption, both of which can often be processed more quickly than domestic private adoptions.” I am wondering how the author came to this conclusion.
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August
2010
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BY
Jean-Luc Bourdon
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Article
By now, CPAs have heard much about Roth IRA conversions made widely available in 2010. Take the following test to see how much you’ve learned. TRUE OR FALSE? 1. Starting in 2010, there are no income limitations to make regular contributions to a Roth IRA. 2.
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August
2010
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BY
DAVID LIFSON, CPA
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Article
Revenueraising provisions in the Patient Protection and Affordable Care Act, PL 111148, and the Health Care and Education Reconciliation Act of 2010, PL 111152, like their health care provisions, have farreaching implications. One could even fundamentally change the way we do business and keep records in the United States—by dramatically increasing information reporting requirements for business transactions.
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August
2010
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BY
KEVIN E. PACKMAN, ESQ., MAURICIO D. RIVERO, ESQ.
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Article
A key component of the federal government’s push for heightened tax compliance among U.S. taxpayers with foreign accounts and assets is the Foreign Account Tax Compliance Act (FATCA). In an interview in February this year with the JofA, IRS Commissioner Doug Shulman called the thenpending legislation “the next big thing” in international tax compliance and enforcement (“Tax From the Top Q&A With IRS Commissioner Doug Shulman,” JofA, April 2010, page 16).
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August
2010
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BY
DONALD L. ARIAIL, CPA/CFF, MICHAEL M. SMITH, ESQ., CPA, NEIL DEININGER, ESQ., CPA, REBA M. WINGFIELD, ESQ.
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Article
With the downturn in the economy and massive job losses, personal bankruptcy filings have exploded. According to the National Bankruptcy Research Center, approximately 1.4 million bankruptcies were filed in 2009, a 32 increase over 2008. They included Chapter 7 bankruptcy filings, which increased 42, and Chapter 13 filings, which increased 12.
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August
2010
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BY
Karen Nakamura, CPA, Jason R. Thompson, Esq., LL.M., Tara Ferris, Esq., LL.M.
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Article
State net operating loss (NOL) rules generally differ from federal NOL rules, and state NOL rules often differ from one another. This is especially true with respect to carrybacks of NOLs—which, unlike for federal returns, the majority of states do not allow—and carryforwards. This lack of consistency can lead to confusion about a taxpayer’s ability to use NOLs.
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August
2010
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BY
PAUL BONNER
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Article
The AICPA and other accounting, legal and business groups called upon the IRS to withdraw its proposed requirement that businesses above a $10 million asset threshold report their uncertain tax positions. The groups responded to the IRS’ request for comments on its three announcements earlier in the year (20109, 201017 and 201030), with the latest unveiling a draft Schedule UTP that would be attached to the returns of affected taxpayers.
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August
2010
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BY
Charles J. Reichert, CPA
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Article
The Tax Court recently denied motions of the IRS to vacate and reconsider its prior decision in Intermountain Insurance Service of Vail LLC v. Commissioner, TC Memo 2009195, in light of new Treasury regulations issued approximately one month after that case was decided. (For prior Tax Matters coverage, see “Application of SixYear Statute of Limitations Denied Again,” Nov.
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August
2010
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BY
Karyn Bybee Friske, CPA, Ph.D., Darlene Pulliam, CPA, Ph.D.
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Article
In a second decision (Pierre II) involving Suzanne Pierre’s transfer of a singlemember limited liability company (LLC) interest to two trusts, the Tax Court applied the step transaction doctrine to the gift and sale transactions at issue in the case and slightly reduced the lackofcontrol discount. Previously, the court had ruled that the transfer of an interest in a singlemember LLC should be valued for gift tax purposes as a transfer of an interest in the LLC rather than a transfer of its underlying assets, despite the fact that the LLC was a disregarded entity under the
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August
2010
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Article
SUPREME COURT WON’T REVIEW TEXTRON The U.S. Supreme Court declined to review Textron Inc. v. U.S. (Sup. Ct. docket no. 09750), letting stand a First Circuit Court of Appeals decision that the work product privilege did not protect the corporation’s tax accrual workpapers from an IRS summons. For the First Circuit’s decision, see U.S.
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