The Tax Adviser

Estate of McKelvey highlights potential tax pitfalls of variable prepaid forward contracts

Andrew McKelvey was the founder and former CEO of Monster Worldwide Inc. As such, he held a large amount of Monster stock with zero basis. The amount of stock to be delivered was determined by a ...
The Tax Adviser

Recent developments in estate planning

This annual update summarizes key changes advisers need to be aware of to ensure their clients’ estate plans remain effective and in line with their intentions. It covers developments in the estate ...
The Tax Adviser

R&D tax credits: A new era of disclosure and documentation

Editor: Jessica L. Jeane, J.D. While Harper ultimately prevailed, the case underscored a broader issue: Taxpayers cannot expect IRS audit action to validate claims that are procedurally weak at filing ...
The Tax Adviser

Sec. 382 and exceptions to the segregation rules

Editor: Jessica L. Jeane, J.D. The rules relating to aggregation and segregation are rules of convenience and presumption. However, if the corporation has actual knowledge of the ownership of certain ...
The Tax Adviser

IRS renews corporate tax opportunities with letter rulings

Editor: Jessica L. Jeane, J.D. Secs. 332, 351, 368, and 1036. As a consequence, full no-gain-or-loss rulings are available under Secs. 332 (corporate subsidiary liquidation into its corporate owner); ...