Section 678Grantor TrustIncome TaxThis article explores Section 678 of the Internal Revenue Code and how and when a beneficiary is deemed to be the owner of a trust for income tax purposes (calldoi:10.2139/ssrn.3165592Morrow, Edwin PSocial Science Electronic Publishing...
tax determined under section 6411(b) is otherwise prevented by the operation of any law or rule of law other than section 7122, such application, credit, or refund may be allowed or made if application for a tentative carryback adjustment is made within the period provided in section 6411(a...
CLICK HERE to return to the home page Internal Revenue Code Section 50(b)(2) Other special rules (b) Certain property not eligible. No credit shall be determined under this subpart with respect to— (1) Property used outside United States. (A) In general. Except as provided in sub...
Gifting IRC Section 403(b) AssetsTHE EASIEST WAY TO DONATE ASSETS is for the participant to name the tax-exempt employer as the designated beneficiary of the account.Smilowitz, Mitchell JCpa Journal
In this paper, we discuss the legislative history of Code Section 6103 and its precursors which provide for disclosure of tax returns to shareholders who own more than one percent of the capital stock. We then provide examples of the valuable proprietary information that is included in corporate ...
A schematic look at IRC [section] 2503(c) trusts for minors. (Financial Planning Tax Tactics).Rywick, Bob
Section 165(c)(2) deductions also frequently prompt IRS oversight, and in many instances, the standard tax preparation software does not adequately address this deduction, since it's generally geared to the more familiar section 1211 capital loss treatment. But while section 1211 is an appropriate...
IRC Section 1031 Tax-Deferred ExchangesInternational Red CrossTax-deferred ExchangesAbilitiesTaxesGainsIntermediariesSellersReplacementUsing Tenancy-in-Common Interests as Replacement PropertyMaples, LarryCaldwell, Charles WWood, Bob G., Jr...
Section 1041 is relatively straightforward and easily understood. Complexity enters the analysis in the area of those transactions and sections of the Code that may conflict with 搂1041. These situations, including assignment of income, stock redemptions of closely held corporate stock, and stock ...
Private Letter Ruling Issued Addressing the Public Benefit Exception Under IRC Section 118(b) Relating to Contributions in Aid of ConstructionMartha Groves PughPhilip Tingle