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The Tax Adviser back issues
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FBAR penalties reduced for six months.(Report of Foreign Bank and Financial Accounts)
June 1, 2009... The IRS has provided a framework for voluntary disclosure requests containing offshore issues, such as previously undisclosed foreign financial accounts and entities (March 23, 2009, memo from Deputy Commissioner Linda Stiff to LMSB and SB/SE commissioners). The policy will remain in place...
Prop. regs. on determining partners' distributive shares.
June 1, 2009... The IRS has issued proposed regulations on determining partners' distributive shares of partnership items of income, gain, loss, deduction, and credit when a partner's interest varies during a partnership tax year (REG-144689-04). The proposed regulations also modify the existing regulations...
IRS continues to challenge deferral of revenue from gift cards.
June 1, 2009... In recent years, due to the increasing use of gift cards and the disparity between the federal tax accounting and financial accounting treatment of advance payments, there has been inconsistency among taxpayers and confusion as to the proper timing of recognizing income from gift cards. One...
Recognizing unbilled revenue.
June 1, 2009... In Technical Advice Memorandum (TAM) 200903079, the IRS applied the all-events test for income recognition to service contacts that were subject to the Federal Acquisition Regulations (FAR), 48 CFR Chapter 1. This article discusses the IRS's interpretation and application of the Sec. 451...
Tax Court addresses claim of offset against deferred payments.
June 1, 2009... In a Tax Court case published on January 28, 2009, Trinity Industries, Inc., 132 T.C. No. 2, the court required the taxpayer to accrue in income, in the year it is earned, the total contract price for the sale of barges--including amounts withheld by customers against deferred payments...