Preparing for an estate tax examination

Article Abstract:

Estate tax examinations are quite different than income tax examinations and typically require representation by a lawyer, CPA, or enrolled representative who has expertise in estate tax law. Estate examinations differ from income tax examinations in that the taxpayer is deceased, which leads to problems in locating assets and supporting records. Estate tax returns list the taxpayer's assets and debts at the time of death and typically include property transfers made during the taxpayer's life. Estate tax examinations often involve questions concerning the value of the taxpayer's property. The IRS examiner, typically a lawyer who may also be a CPA, is instructed to pursue only 'significant' issues. Significance is based on many factors, including: inherent character of the item, the absolute and comparative size of the item, and the evidence of fraud.

Methods, Tax accounting, Accounting and auditing, Transfer taxes, United States. Internal Revenue Service

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Transfer pricing tax concerns for global financial companies

Article Abstract:

Financial business entities which conduct international operations increasingly are subject to transfer pricing tax rules affecting their global transactions. Procedural and enforcement issues arise for businesses and taxing authorities. Reference to several proposed methods for transfer pricing may be useful. Beneficial income allocations are possible as long as necessary record keeping is instituted for avoidance of IRC sections 482 and 6662 adjustments and penalties.

Tax Law, Public Finance Activities, Tax Administration, United States, Taxation, International business enterprises, Multinational corporations, Tax administration and procedure, Financial institutions, Transfer pricing, international

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