The Tax Adviser

Issue Date: 06/01/1995

In This Issue

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1. Availability of 10-year carryback should be considered in light of IRS's... In Letter Ruling 9441020, the IRS determined that specified liability losses under Sec. 172(f) included losses incurred due to state tax assessments, the interest on ... (PERIODICAL ARTICLE) 2. TAM 9452002: redefining "control." (Technical Advice Memorandum) In Letter Ruling (TAM) 9452002, the IRS has in one document summarized the entire body of law on voting stock and the affiliation requirement for ... (PERIODICAL ARTICLE) 3. Increasing-annuity payments make GRAT more attractive. An increasing-annuity grantor retained annuity trust (GRAT) can be used to increase the amount of property that passes to the remainder beneficiaries without generating a ... (PERIODICAL ARTICLE) 4. Gift tax return SOL - exception to the general rule. A deficiency for gift tax generally must be assessed within three years after the gift tax return was filed (Sec. 6501(a)). However, Sec. 6501(c) provides ... (PERIODICAL ARTICLE) 5. Attribution rules applicable to commercial activities or controlled... Until recently, a foreign person subject to tax in the United States was required to consider the U.S. related party rules only in a fairly ... (PERIODICAL ARTICLE) 6. Filing of Form 3115 may be necessary by June 19, 1995 to obtain automatic... Final regulations addressing the requirement to capitalize interest expense under Sec. 263A(f) with respect to the production of property were issued in December 1994, effective ... (PERIODICAL ARTICLE) 7. Pitfalls under new sec. 959 ordering rules. In the Revenue Reconciliation Act of 1993, Congress expanded the antideferral regime of subpart F by amending the ordering rules of Sec. 959, Exclusion from ... (PERIODICAL ARTICLE) 8. When does the cash method clearly reflect income? In recent years, the IRS has increasingly challenged the use of the cash receipts and disbursements method of accounting by taxpayers in service businesses. Because ... (PERIODICAL ARTICLE) 9. Property transferred in connection with performance of services. The recently proposed amendments to the regulations under Sec. 83(h) would eliminate a special rule that requires an employer to deduct and withhold income tax ... (PERIODICAL ARTICLE) 10. Field directive says part-timers cannot be excluded. The Service has issued a field directive providing guidance on the exclusion of part-time employees under Sec. 410. In essence, the IRS National Office has ... (PERIODICAL ARTICLE)
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