January 2015 - The Tax Adviser

IRS Disagrees With Tax Court on Ability to Designate Employment Tax Payments as Income Tax Withholding

Procedures for Withholding Foreign Partnerships and Withholding Foreign Trusts Coordinated With FATCA

IRS Allows Sec. 1298(f) Filing Exemption for Certain Holders of Marked-to-Market PFIC Stock

LB&I Explains “Rules of Engagement” in Examinations of Transfer-Pricing Issues

New Revenue Recognition Standard Has Significant Implications for Tax Accounting and Return Preparation

Changing Method of Accounting to Comply With New Retail-Inventory Method Regulations

IRS Releases Regulations Related to Hybrid Pension Plans

IRS Provides Guidance on Implementing Pension Funding Relief Rules

IRS Finalizes Regulations on Use of QLACs

IRS Issues Final Regulations on Sec. 162(m)(6) Deduction Disallowance

Active Members of an Investment Adviser LLC Are Subject to Self-Employment Tax

Using Loans to Extract Cash From a Closely Held Corporation

Congress and the Extenders: Doing the Same Thing Over and Over and Expecting Different Results

Proposed Regulations Would Change Treatment of Sec. 751 Property

Nonpayment Testing Period Would Be Eliminated Under Proposed Regulations

IRS Updates Streamlined Offshore Compliance Procedures

IRS Issues Final Regulations on Allocation of Earnings and Profits

Economic Substance Doctrine Clarified

Deferred Annuities in Defined Contribution Plans Can Be Offered to Older Participants

Basis Allocation to Nonshareholders in All-Cash D Reorganizations Prohibited

2015 Inflation Adjustments Announced

When to Rely on a Tax Adviser’s Advice as “Reasonable Cause”

What to Do When Your Client Receives a Summons

IRS Analyzes Whether Third-Party Employment Tax Returns Are Sufficient to Start Assessment Statute of Limitation

Taxpayers Do Not Have Standing to Challenge Parsonage Exemption

Taxpayer Has Ordinary Income From Merger-Related Payment

2014 Arthur J. Dixon Memorial Award