Preparing for an estate tax examination
Estate tax examinations are quite different than income tax examinations and typically require representation by a lawyer, CPA, or enrolled representative who has expertise in estate tax law. Estate examinations differ from income tax examinations in that the taxpayer is deceased, which leads to problems in locating assets and supporting records. Estate tax returns list the taxpayer's assets and debts at the time of death and typically include property transfers made during the taxpayer's life. Estate tax examinations often involve questions concerning the value of the taxpayer's property. The IRS examiner, typically a lawyer who may also be a CPA, is instructed to pursue only 'significant' issues. Significance is based on many factors, including: inherent character of the item, the absolute and comparative size of the item, and the evidence of fraud.
Publication Name: Taxation for Accountants
Transfer pricing tax concerns for global financial companies
Financial business entities which conduct international operations increasingly are subject to transfer pricing tax rules affecting their global transactions. Procedural and enforcement issues arise for businesses and taxing authorities. Reference to several proposed methods for transfer pricing may be useful. Beneficial income allocations are possible as long as necessary record keeping is instituted for avoidance of IRC sections 482 and 6662 adjustments and penalties.
Publication Name: Taxes: The Tax Magazine
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- Abstracts: Mimicking portfolios and exact arbitrage pricing. Mean-variance spanning. Contagious speculation and a cure for cancer: a nonevent that made stock prices soar
- Abstracts: Small business meets tax reform '86. Eliminating fraud in financial reporting. How will small companies fare in the late Eighties?
- Abstracts: Structure and agency in an institutionalized setting: the application and social transformation of control in the Big Six
- Abstracts: Lessons from liability claims. Lessons form auditing claims. A policy for insurance