2010 Articles

4-1-1: PTIN Registration By Michelle L. Heller October 2010 As of September 28, 2010, online registration is available for obtaining a Preparer Tax Identification Number. If you already have a PTIN, you are still required to complete the application/registration.

Administrative problems with the increased Form 1099 reporting requirements By Eric Blackledge October 2010 A look at the burdens to businesses and to the IRS imposed by the new 1099 requirements of the Health Care Reform legislation.

Chair’s corner By Michelle L. Heller October 2010 A note from Chair Michelle Heller.

Estate tax issues By Thomas F. Arends October 2010 The debate surrounding the estate tax centers on the amount of the exemption and the rate. As to the particular exemption levels and the tax rate, the ISBA's Federal Taxation Section supports a permanent exemption level of at least $3.5 million, provided it is indexed for inflation. The Section does not support any rate in excess of 45 percent.

New financial reporting rules and proposed IRS rules would raise the stakes on taking aggressive tax positions By Edward J. Hannon & Michelle B. Baxter May 2010 Two recent changes to financial reporting and tax return disclosure rules could impact whether taxpayers will choose to take tax positions that have a significant chance of being challenged by the IRS.

Offers in Compromise By William M. Gasa October 2010 These comments are a follow-up and expansion of the Federal Taxation Section's 2007, 2008 and 2009 Offers in Compromise reports.

Proposed technical correction to Section 7430 By George E. Marifian October 2010 This article addresses the need to harmonize Section 7430(c)(7)(B) with Section 7430(c)(2)(B) of the Internal Revenue Code.

Who wants cake? Section 368 tax-free reorganizations for corporations By Derek P. Usman May 2010 By utilizing the reorganization exit strategy, business owners are able to sell their business while deferring their gain.

With great power comes great responsibility—Deferring cancellation of debt income for tax partnerships By Brian A. Smith & William E. Russell May 2010 The American Recovery and Reinvestment Act of 2009 became effective on February 17, 2009, and many questions regarding how the cancellation of indebtedness (COI) deferral election applies to partnership situations still remain unanswered.