Provision making number of shares contingent on revaluation held invalid by IRS

Article Abstract:

A provision that would increase the number of shares that are received by shareholders when the shares are revalued was ruled contrary to public policy as stated in TAM 8549005. One result of the ruling is that a gift tax will be due on the difference because the value of the shares given up by taxpayers in an estate planning reorganization will be held to be more than the value of shares received. The reasons the TAM decided that the gift tax applied and the cases that weighed on its decision are discussed.

Securities, Corporations, Valuation, Securities taxes

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Substantiation rules repealed at a cost of reduction in ITC and ACRS benefits

Article Abstract:

The government will repeal the substantiation regulations for listed property (including cars), which covers the assets used both for personal and business purposes, following approval by the president. The law that reinstates the substantiation regulations of Section 274 covers these types of assets included in the taxpayer's business or trade. Consequently, to generate new income, the top investment tax credit has been cut for the purchase of an automobile for business use.

Analysis, Tax accounting

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New regulations still call for strict recordkeeping for business use of cars

Article Abstract:

Tax benefits associated with the business use of personal and company automobiles have been limited by the Deficit Reduction Act of 1984. There are new substantiation rules which restrict the deductions to those supported with current records. Despite a public uproar and a partial repeal of some of the measures governing tax deductions for the use of cars in business, there has been little abuse or overuse of the tax deduction.

Tax deductions

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