Page 544 - TaxAdviser_2022

Volume 53, Number 11 November 2022

TAX CLINIC

M&A transactions: Deducting
accrued liabilities ............................7
Updated simplified method
for estate portability elections ....... 9

Scholarship grants awarded
by private foundations ............... 10
Deduction of startup expenses ... 11

CFCs: US shareholders’
income inclusions ....................... 12

Real property losses are
capital, not ordinary .................... 17
Distribution of risk in captive
insurance companies .................. 18
Inadvertent terminations of S
and QSub elections ..................... 20
Sourcing Sec. 751(a) gain
from nonresident’s sale of
26 Recent developments in estate California partnership interest ..... 21
planning: Part 1 All-events test for sales
incentives — one perspective ..... 23
By Justin Ransome
All-events test for sales
In this first installment of an annual update on trust, estate, and gift taxation, the incentives — another
topics include estate tax closing letters, the basic exclusion amount, estate debts perspective .................................. 24
and expenses, and extending the time to elect portability. The second and third
installments of the annual update will appear in the December and January issues,
DEPARTMENTS
respectively.
38 Federal implications of passthrough TAX PRACTICE
entity tax elections RESPONSIBILITIES ...................... 48

By Lynn Mucenski-Keck and Jeremias Ramos CAMPUS TO CLIENTS ................. 52
Many questions remain with respect to the deductibility at the federal level of state CASE STUDY ................................ 56
income tax payments (SITPs) made by passthrough entities (PTEs) under new state
tax regimes enacted to ameliorate the effect of the cap for individuals on the deduc- TAX TRENDS ................................. 60
tion of state and local taxes. This article discusses some of those questions, as well as
whether a state refund of credits received by PTE owners related to SITPs is includ- Tax News
ible in their income.
For the latest tax news, visit
TheTaxAdviser.com.
On the cover and above: Images by smartboy10/Getty Images

2 November 2022 The Tax Adviser