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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
14 Supporting organization loses
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