A "related person" means a person who is related to the taxpayer for purposes of IRC Section 267(b) or IRC Section 707(b). In addition, actions taken by a delegate or agent are attributed to the principal for purposes of the ATB ...
Demystifying IRC Section 965 MathLougen, Mary BethCPA Journal
IRS ISSUES LETTER RULING ON CAPITAL CONTRIBUTIONS AND THE SECTION 382 LIMITATION. The article offers information on the Letter Ruling 201251002 (9/24/12) issued by the U.S. Internal Revenue Service regarding capital contributions faced b......
(ii) the taxpayer shall be considered to have purchased property or stock only if, but for the provisions of subsection (b) of this section, the unadjusted basis of such property or stock would be its cost within the meaning of section 1012. (B) Period within which property must be repl...
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...
Subparagraph (A) shall not apply to any sale to, or exchange with, any person who bears a relationship to the taxpayer which is described in section 267(b) or 707(b). (9) Members of uniformed services and foreign service — (A) In general — ...
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...
A schematic look at IRC [section] 2503(c) trusts for minors. (Financial Planning Tax Tactics).Rywick, Bob
Private Letter Ruling Issued Addressing the Public Benefit Exception Under IRC Section 118(b) Relating to Contributions in Aid of ConstructionMartha Groves PughPhilip Tingle
by John L. OlsenCLU®ChFC®AEP® andMichael E. KitcesCLU®ChFC®CFP®MSFSMSTAX