Built-in gain Prop. Regs. provide planning opportunities
Article Abstract:
The IRS has released Proposed Regulations that clarify the provisions of Section 1374, with respect to S corporation procedures for inventory valuation and the reporting of built-in gains using the installment method. The Proposed Regulations also elaborate on the accounting of pass-through items of partnerships and the modifications of Section 481 arising from procedural changes in accounting. Under Section 1374, C corporations that elect S status are effectively deterred from liquidating assets at a single tax level for appreciation realized by the C corporation and other items of income. The Proposed Regulations elaborate on the procedures that are used to determine the tax due on built-in gain arising from the election of S status. These procedures include a four-step tax assessment process that is mandatory for C corporations that convert into S corporations after 1986.
Publication Name: Taxation for Accountants
Subject: Business
ISSN: 0040-0165
Year: 1993
User Contributions:
Comment about this article or add new information about this topic:
Prop. Regs. expand protection to plans accepting rollovers
Article Abstract:
Proposed Regulations extend the relief from disqualification that was included in the Final Regulations introduced in 1995 to plans accepting rollover contributions from employees. The Proposed Regulations add other situations that result in the failure of a distribution to be a qualified rollover distribution as long as the plan administrator reasonably judges that the requirements were met. Therefore, a plan will not be ineligible because the requirements for matching contributions or the limits on contributions are not satisfied because of the reclassification. The disqualification relief also covers rollover contributions to a plan from an employee within 60 days of a distribution from another plan or from a conduit individual retirement account. Corrective action must be made when the mistakes are discovered.
Publication Name: Taxation for Accountants
Subject: Business
ISSN: 0040-0165
Year: 1996
User Contributions:
Comment about this article or add new information about this topic:
Steps to take when a partnership is being audited
Article Abstract:
The new TEFRA rules for partnership audits introduce radical procedural changes in the audit of partnership returns. The new unified audit rules are outlined in Sections 6221 through 6231 and are intended to enable the centralization of the administrative review and litigation proceedings involving partnership audits. The TEFRA rules allow tax adjustments, deductions and credits to be audited at the partnership level, even when the tax liabilities are assessed at the partner level. The new unified audit rules apply to all partnerships that have over 10 partners. An exemption from the TEFRA audit procedures is provided only for smaller partnerships that meet certain criteria.
Publication Name: Taxation for Accountants
Subject: Business
ISSN: 0040-0165
Year: 1992
User Contributions:
Comment about this article or add new information about this topic:
- Abstracts: Tax liens and levies involving partners: will a partnership's assets be attached?
- Abstracts: Researching minorities. Thoughts on readership research. What we have learned from researching AIDS
- Abstracts: US-Soviet cooperation in space: benefits, obstacles and opportunities. part 2 Estimating the life cycle cost of the Space Exploration Initiative
- Abstracts: Efficiency in financial services firms. The importance of relationships to the availability of credit. Repeated acquirers in FDIC assisted acquisitions
- Abstracts: 'Private' split-dollar provides transfer tax savings. Using Crummey powers in trusts for annual giving. Life insurance trusts offer tax savings and liquidity