Article: Rep. Berman Introduces Tom Lantos and Henry J. Hyde U.S. Global Leadership Against HIV/AIDS, Tuberculosis, and Malaria Reauthorization Act

Article: Sec. 1245 recapture rules can apply to stock.
The Tax Adviser;  June 1, 2009 ;     700+ words ...Sec. 1245 recapture rules require a taxpayer to characterize gain on the disposition of certain depreciable...of stock. This item discusses how a reduction in a debtor's stock basis through application of the Sec. 108 attribute reduction rules can result in Sec. 1245 recapture on a disposition of that ...

Article: Practical tax planning for sec. 303 stock redemptions.
The Tax Adviser;  February 1, 1997 ;     700+ words ...Sec. 303, which permits redemptions of stock owned by estates...is much more liberal a provision than it initially appears. Sec. 303 actually allows an infusion of cash into an estate or...opportunities. These opportunities and the basic workings of Sec. 303 are addressed in this article's many examples. ...

Article: Allocation and apportionment of expenses for Sec. 199 purposes: for many taxpayers, calculation of the Sec. 199 deduction will require an enormous amount of work. This article focuses on one aspect of the deduction, the allocation and apportionment of expenses under the Sec. 861 regulations and the proposed Sec. 199 regulations.
The Tax Adviser;  June 1, 2006 ;     700+ words ...EXECUTIVE SUMMARY * Sec. 861 REGULATIONS are integral to the Sec. 199 deduction when the Sec. 861 method of allocating deductions is used. * Regs. Sec. 1.861-8 provides specific allocation rules for some expenses, such as interest and R&E, and...

Article: Sec. 1202 qualifications.(IRC section 1202, capital gains tax exclusion)
The Tax Adviser;  August 1, 1999 ;     700+ words ......Revenue Reconciliation Act of 1993 created Sec. 1202, which allows noncorporate investors...for more than five years to qualify for Sec. 1202 treatment; the stock must have been...1998. Practitioners now need to consider if Sec. 1202 applies to their clients' transactions...

Article: Closer scrutiny of state and local plans by Sec. 415.
The Tax Adviser;  October 1, 1992 ;     700+ words ...The effects of Sec. 415 on potential state retirees requires...that satisfies aH of the requirements of Sec. 401(a) will be exempt from Federal taxation...of the participants. * In accordance with Sec. 414(h), employee contributions may be picked...

Article: Basis calculations and reporting requirements for sec. 1244 stock. (Tax Court Memorandum opinions in Bledsoe and Schwartz)
The Tax Adviser;  November 1, 1996 ;     700+ words ......recent cases will affect how taxpayers with Sec. 1244 stock compute their tax bases in the...designated as being made in exchange for Sec. l@,u shares qualify for ordinary loss treatment...statement to the return of a taxpayer claiming a Sec. 1244 loss, now, the taxpayer must only...

Article: IRS is rethinking its position on sec. 1031 followed by a corporate reorganization.
The Tax Adviser;  May 1, 1997 ;     700+ words ...Sec. 1031(a)(1) provides that no gain or loss shall be recognized...use in a trade or business or for investment. Pursuant to Sec. 1031(a)(3), any property received by the taxpayer (the replacement...corporation may be in the middle of satisfying the requirements of Sec. 1031(a)(3) when it becomes involved ...

Article: Are cooperative apartments membership organizations for purposes of sec. 277?
The Tax Adviser;  July 1, 1996 ;     700+ words ...Sec. 216 provides that tenant-shareholders of a cooperative housing...pay monthly rent (maintenance) to the co-op. The purpose of Sec. 216 is to put tenant-shareholders on the same footing as...attributable to their cooperative units. A limitation on using Sec. 216 is that income from sources other than ...

Article: Reducing losses disallowed by sec. 197.
The Tax Adviser;  July 1, 1996 ;     700+ words ...Since its enactment in 1993, Sec. 197 has reduced significantly the level...and the IRS, not all issues arising under Sec. 197 have been identified or resolved...application of the loss disallowance rules in Sec. 197(f), which affects taxpayers as they...

Article: Caveat: recent letter ruling raises issue of whether sec. 304 applies in domestic spin-off transaction. (Brief Article)
The Tax Adviser;  June 1, 1993 ;     283 words ...In a recently issued favorable Sec. 355 letter ruling, the IRS declined to rule on whether Sec. 351, 368(a)(1)(D) or 304, or Regs. Sec. 1.1502-80(b), applied to an asset transfer that preceded a spin-off transaction. The transaction involved a transfer...

Article: Does a sec. 457 plan work with a sec. 501(c)(7) organization? (retirement benefit plans)
The Tax Adviser;  September 1, 1993 ;     700+ words ...Many membership organizations exempt under Sec. 501(c)(7), especially country clubs, have established Sec. 457 deferred compensation plans for their...taxable income, with no offsetting deductions. Sec. 512(a)(3) requires a Sec. 501(c)(7) organization...

Article: Expensing depreciable assets; proposed Sec. 179 regulations clarify recent tax act changes.
The Tax Adviser;  January 1, 1992 ;     700+ words ...Proposed Sec. 179 Regulations Clarify recent Tax Act Changes...IRS published proposed regulations on the Sec. 179 election to expense certain depreciable...regulations, which incorporate changes to Sec. 179 made by the Technical and Miscellaneous...

Article: The ins and outs of sec. 197. (acquired intangibles)
The Tax Adviser;  October 1, 2006 ;     700+ words ...Sec. 197 covers the proper tax treatment for most acquired intangible...life. For intangibles assets acquired after Aug. 10, 1993, Sec. 197 removed the uncertainty, by promulgating a list of intangibles...purposes over a 15-year life. Certain intangibles are outside Sec. 197's scope and are subject to ...

Article: Interaction between Sec. 1202 and other provisions.(gains from sale or exchange of small business stock; LLCs)
The Tax Adviser;  December 1, 2000 ;     700+ words ...Sec. 1202(a) allows taxpayers other than corporations to exclude...start-up firms. Since the passage of the current version of Sec. 1202 in 1993, all states have enacted limited liability company...treatment of LLCs, promulgated the check-the-box rules in Regs. Sec. 301.7701-3. These rules allow a ...