Page 548 - TaxAdviser_2022

TAX CLINIC
Practical advice on current issues.
Editor:
Mark G. Cook, CPA, CGMA
All contributors are members of
SingerLewak LLP.
For additional information about
these items, contact Mr. Cook
at 949-623-0478 or
mcook@singerlewak.com.
6 November 2022
In This Department
CORPORATIONS & PROCEDURE &
SHAREHOLDERS ADMINISTRATION
M&A transactions: Deducting Distribution of risk in captive
accrued liabilities; p. 7. insurance companies; p. 18.
ESTATES, TRUSTS & GIFTS S CORPORATIONS
Updated simplified method IRS applies Sec. 1362(f) to relieve
for estate portability elections inadvertent terminations of S and
available; p. 9. QSub elections; p. 20.
EXEMPT ORGANIZATIONS STATE & LOCAL TAXES
Scholarship grants awarded by Sourcing Sec. 751(a) gain from
private foundations; p. 10. nonresident’s sale of California
partnership interest; p. 21.
EXPENSES &
DEDUCTIONS TAX ACCOUNTING
Deduction of startup expenses; All-events test for sales incentives
p. 11. — one perspective; p. 23.
FOREIGN INCOME & All-events test for sales incentives
TAXPAYERS — another perspective; p. 24.
Controlled foreign corporations:
US shareholders’ income
inclusions; p. 12.
GAINS & LOSSES
Real property losses are capital,
not ordinary, Tax Court holds;
p. 17.
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