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TOPICAL CONTENTS

EXPENSES & DEDUCTIONS
7 Implications of legislative changes for
R&E and software development costs

FOREIGN INCOME
& TAXPAYERS

41 Foreign earned income exclusion:
Pandemic-related relief

GAINS & LOSSES
9 Gain recognition agreements: US
corporation’s transfer of a foreign
corporation followed by the foreign
corporation’s disposition of its assets

BOTTOM LEFT: PHOTO BY SOLSTOCK/ISTOCK; TOP RIGHT: IMAGE BY SOLARSEVEN/ISTOCK; BOTTOM RIGHT: IMAGE BY ISCATEL57/ISTOCK

PROCEDURE & TAX ACCOUNTING
ADMINISTRATION 19 Sec. 451 regulations offer ways

16 Interest claim limitation periods, to reduce revenue acceleration
including for ‘net rate’ netting claims
36 Passport revocation as a collection
tool
40 Adequate disclosure and the IRS’s
strategy of more information reporting
48 Late-filed petition does not deprive
Tax Court of jurisdiction over case
50 IRS litigators not bound by
innocent-spouse determination
GROSS INCOME S CORPORATIONS

44 Tax consequences of real property 22 Current developments in
foreclosures S corporations

PARTNERS & Opinions expressed in The Tax Adviser are those of the individual writers and may differ from policies of the American Institute
PARTNERSHIPS of Certified Public Accountants, the Tax Division, or its other divisions and committees. This publication is designed to provide
accurate and authoritative information on the subjects covered. It is sold, however, with the understanding that the publisher,
editors, and authors are not engaged in rendering legal, accounting, or other professional service. If specific tax advice or
12 Nonliquidating distributions: Ways other expert assistance is required, the services of a competent professional person should be sought. The information in this
publication is not intended or written to be used as, and cannot be used as or considered to be, written tax advice, and should
to determine basis
not be relied on for the purpose of (1) avoiding tax-related penalties under the Internal Revenue Code or (2) promoting, marketing,
14 A practical guide to partnership or recommending to another party any transaction or tax-related matter(s) addressed herein, for IRS audit, tax dispute, or other
purposes. The contents of The Tax Adviser are indexed in ProQuest Accounting & Tax, a product of ProQuest, available online,
division planning www.proquest.com.

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