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TOPICAL CONTENTS
CORPORATIONS &
SHAREHOLDERS
7 M&A transactions: Deducting
accrued liabilities
ESTATES, TRUSTS & GIFTS
9 Updated simplified method for estate
portability elections available
26 Recent developments in estate
planning: Part 1
EXEMPT ORGANIZATIONS
10 Scholarship grants awarded by
private foundations
EXPENSES & DEDUCTIONS
11 Deduction of startup expenses
56 Employer-provided and
company-owned vehicles
FOREIGN INCOME & GAINS & LOSSES STATE & LOCAL TAXES
TAXPAYERS 17 Real property losses are capital, not 21 Sourcing Sec. 751(a) gain from
ordinary, Tax Court holds nonresident’s sale of California
12 Controlled foreign corporations: US
partnership interest
shareholders’ income inclusions PRACTICE &
60 Engineer cannot escape closing PROCEDURES 38 Federal implications of passthrough
agreement entity tax elections
48 Proposed AICPA tax standards 64 Fulfillment by Amazon program
address new concerns does not create nexus with Pennsylvania
PROCEDURE & TAX ACCOUNTING
ADMINISTRATION 23 All-events test for sales incentives —
18 Distribution of risk in captive one perspective
insurance companies 24 All-events test for sales incentives —
BOTTOM LEFT: IMAGE BY PAKIN SONGMOR/GETTY IMAGES; TOP RIGHT: IMAGE BY PM IMAGES/GETTY IMAGES inadvertent terminations of S and QSub 52 Practice and policy insights from
another perspective
S CORPORATIONS
TAX EDUCATION
20 IRS applies Sec. 1362(f) to relieve
academic tax research
elections
Opinions expressed in The Tax Adviser are those of the individual writers and may differ from policies of the American Institute
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
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
not be relied on for the purpose of (1) avoiding tax-related penalties under the Internal Revenue Code or (2) promoting, marketing,
purposes. The contents of The Tax Adviser are indexed in ProQuest Accounting & Tax, a product of ProQuest, available online,
www.proquest.com.
November 2022 3
www.thetaxadviser.com or recommending to another party any transaction or tax-related matter(s) addressed herein, for IRS audit, tax dispute, or other
