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TOPICAL CONTENTS
CORPORATIONS &
SHAREHOLDERS
7 Marrying ESG initiatives to business
tax planning
EMPLOYEE BENEFITS &
PENSIONS
9 Early access to wages may require
new employment tax analyses

PRACTICE & S CORPORATIONS
PROCEDURES 20 IRS provides guidance on perfecting

42 Documentation and recordkeeping S elections and QSub elections
for tax practitioners 22 The ‘one class of stock’ requirement:
54 90-day deadline for filing Tax An interesting letter ruling
Court petition in deficiency case is
jurisdictional STATE & LOCAL TAXES
24 Significant state conformity issues
PROCEDURE & for corporate taxpayers
ADMINISTRATION
GAINS & LOSSES 56 Notice listing syndicated TAX EDUCATION
conservation easement transactions 46 Closing the gap between accounting
12 Determining gross receipts under
held invalid education and the workplace
Sec. 165(g)(3)
14 Issues in allocating income under REAL ESTATE
Sec. 384
17 Recent changes to the Sec. 179D
energy-efficient commercial buildings
deduction

BOTTOM LEFT: PHOTO BY GAWRILOFF/GETTY IMAGES; TOP LEFT: PHOTO BY TOLIMIR/GETTY IMAGES; TOP RIGHT: PHOTO BY TWENTY47STUDIO/GETTY IMAGES; BOTTOM RIGHT: PHOTO BY KENWIEDEMANN/GETTY IMAGES LLCs & LLPs Opinions expressed in The Tax Adviser are those of the individual writers and may differ from policies of the American Institute

50 Dividing an LLC
PARTNERS &
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,
PARTNERSHIPS
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
28 Current developments in partners
not be relied on for the purpose of (1) avoiding tax-related penalties under the Internal Revenue Code or (2) promoting, marketing,
and partnerships
purposes. The contents of The Tax Adviser are indexed in ProQuest Accounting & Tax, a product of ProQuest, available online,
www.proquest.com.
February 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