Pre-Filing Agreement Program Issues Successfully Completed
|
This is a list of all the issues accepted into the Pre-Filing Agreement Program and completed with a closing agreement as of 2/15/13. |
|
Amount of Qualified Research and Experimental Credit |
|
Treatment of License Fee Income |
|
Deductibility of Fees to Purchase Tax Exempt Securities and Stock |
|
Gain/ Loss on Sale/Exchange/Transfer of Stock /Property |
|
Worthless Securities and Bad Debts |
|
Fuel Credit |
|
Writedown of Inventory |
|
Deductibility of Fines/ Penalties/Settlement Fees & Defense Costs |
|
Basis/FMV of Stock Acquired |
|
IRC 199, Domestic Production |
|
Disposition of Subsidiary |
|
Deductibility of Merger/Acquisition Costs |
|
Abandonment Loss |
|
Like-Kind Exchange |
|
Effectively Connected Income |
|
Deductibility of Termination Fee |
|
Interest Deduction |
|
Withholding & Reporting FICA, Interest, Dividends, & Income |
|
Apportionment of General and Admin Expenses |
|
Repatriation of Earnings |
|
Debt Issues |
|
Valuation of Property for Rehab Credit |
|
Loss on Seized Assets |
|
Permanent Establishment |
|
Earnings and Profits |
|
Deductibility of Parachute Payments |
|
Discharge of Indebtedness |
|
Character of Loss |
|
Depreciation Issues – cost segregation study, amortization vs. capitalization, recovery periods, placed in service date |
|
Built in Gain from Acquisition/Sale |
|
Substantiation Required for Tax Deduction |
|
Correction of Overaccrued Tax Liability |
|
Deduction for Collectively Bargained Welfare Benefits |
|
Deductibility of Payments to Retire Debt |
|
Valuation of Assets |
|
Method of Accounting |
|
Stock Basis Computation |
|
Investigatory Costs |
|
FMV of Assets Exchanged for Stock in a Tax-Free Exchange Pursuant to a Reorganization Plan |
|
Deductibility of Fees Incurred in a Reorganization |
|
Bad Debt Deduction for Intercompany Advances |
|
Amount/Utilization of Net Operating Loss |
|
Start-up costs and Operating Expenses |
|
Fair Market Value of Stock Contributed to Pension Plan |
|
Deductibility of Interest |
|
Determination of Whether Taxpayer is a US real Property Holding Company |
|
Amortization of Intangibles |
|
Deductibility of Indemnification Payments |
|
Creditability of Gaming Tax |
|
Eligibility to make a Deemed Sale Election |
|
Involuntary Conversion |
