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TOPICAL CONTENTS


         CORPORATIONS &
         SHAREHOLDERS

         7 Inflation Reduction Act includes 15%
         corporate minimum tax on book income

         EMPLOYEE BENEFITS &
         PENSIONS

         44 Establishing a SIMPLE IRA
         plan for a company with only a few
         employees

         ESTATES, TRUSTS & GIFTS
         24 Recent developments in estate   FOREIGN INCOME &                 PROCEDURE &
         planning: Part 3
                                           TAXPAYERS                         ADMINISTRATION
                                           16 Sec. 987 foreign currency regulations   21 Proposed regs. address IRS Appeals’
                                           applicability date extended again  review of tax controversies
                                                                             50 28 years after assessment, IRS
                                           GROSS INCOME                      collection suit is still timely
                                           48 Taxpayer’s argument for $1.5 million
                                           refund fails on several grounds
                                           LEGISLATION
                                           17 The Inflation Reduction Act’s
                                           energy- and climate-related tax
                                           provisions
                                           PRACTICE MANAGEMENT
                                           40 Working remotely: A tax
                                           practitioner’s checklist
                                           PRACTICE &
                                           PROCEDURES
     BOTTOM LEFT: PHOTO BY YULIA NAUMENKO/GETTY IMAGES;  TOP RIGHT: PHOTO BY TRAVELER1116/GETTY IMAGES;  BOTTOM RIGHT: PHOTO BY PGIAM/GETTY IMAGES  EXEMPT ORGANIZATIONS  37 Chief Counsel memo clarifies the
                                           34 Memo removes IRS procedural
                                           requirements for economic substance
                                           arguments

                                           assessment period in multiyear Sec. 332
                                           liquidations

         11 Private foundations’ distributions to
                                           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
         and from nonpublic charities
                                           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
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                                           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
         tax-exempt status
                                           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.
                                                                                               January 2023  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
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