Tax Executive

Issue Date: 11/01/1991

In This Issue

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1. Comments on proposed notional principal contract regulations. On July 8, 1991, the Internal Revenue Service issued proposed regulations under section 446 of the Internal Revenue Code, concerning the income tax accounting treatment ... (PERIODICAL ARTICLE) 2. Supplemental comments on the use of GAAP to calculate the earnings and... On August 28, 1991, representatives of Tax Executives Institute met with IRS and Treasury representatives to discuss the proposal to use U.S. generally accepted accounting ... (PERIODICAL ARTICLE) 3. Comments on proposed earnings stripping regulations under Section 163(j). On June 12, 1991, the Internal Revenue Service issued proposed regulations under section 163(j) of the Internal Revenue Code, relating to the deductibility of interest ... (PERIODICAL ARTICLE) 4. Comments on proposed information reporting penalty regulations. On behalf of Tax Executive Institute, I am pleased to submit these comments on the Internal Revenue Service's temporary and proposed regulations under sections 6721 ... (PERIODICAL ARTICLE) 5. Comments on proposal to exempt dormant subsidiaries from Form 5471 filing... On behalf of Tax Executives Institute, I am writing to respond to your request for the Institute's comments concerning the filing of the Forms 5471 ... (PERIODICAL ARTICLE) 6. Comments on transfer pricing penalty under Section 6662(e). On February 28, 1991, the Internal Revenue Service issued proposed regulations under sections 6662 and 6664 of the Internal Revenue Code, concerning the accuracy-related penalty ... (PERIODICAL ARTICLE) 7. Nonqualified deferred compensation plans backed by rabbi trusts are... Recent legislation has reduced the benefits available to executives under qualified employee benefit plans and, consequently, has made forms of nonqualified deferred compensation (NQDC) attractive ... (PERIODICAL ARTICLE) 8. A guide to the new proposed regulations under Sections 367(a) and (b). OVERVIEW New proposed regulations under section 367(a) and (b) of the Internal Revenue Code (1) were published in the Federal Register on August 26, 1991. (PERIODICAL ARTICLE) 9. Advance pricing agreements: practical issues to consider in determining... In March, the Internal Revenue Service published Rev. Proc. [91-22,.sup.1+] which sets forth the procedures for taxpayers to follow in applying for an Advance Pricing ... (PERIODICAL ARTICLE) 10. IRS offset program: a case study. Since the Business Master File offset program was resumed, Phillips Petroleum Company has spent considerable time and effort attempting to clear up problems caused by ... (PERIODICAL ARTICLE)
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