Inherited IRA Strategies After The SECURE Act

50th ANNIVERSARY. 50 years of The Tax Adviser. The January 2020 issue marks the 50th anniversary of The Tax Adviser, which was first published in January 1970.Over the coming year, we will be looking back at early issues of the magazine, highlighting interesting tidbits.

Actived: Friday May 22, 2020


IRS finds future costs of fuel rewards are subtracted from

More recently, in Giant Eagle, Inc., T.C. Memo. 2014-146, rev'd on other grounds, 822 F.3d 666 (3d Cir. 2016), the Tax Court ruled that discount coupons are not premium coupons subject to Regs. Sec. 1. 451-4 and, therefore, the taxpayer in Giant Eagle could not offset current-year sales revenues by its estimated future cost of redeeming

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Taxation of Worthless and Abandoned Partnership Interests

If Sec. 165(g) applies, Sec. 165(a) does not. A security for Sec. 165(g) purposes includes corporate stock and stock options as well as corporate or government debt that is registered or has interest coupons. 6 The securities at issue met this definition. Gold Kist did not apply Sec. 165(g) because the securities were not worthless as evidenced

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IRS guidance offers useful reminders about employee

Background. Sec. 132(a)(2) allows employers to provide a qualified employee discount that is excludable from an employee's taxable income. A qualified employee discount is defined under Sec. 132(c) as a discount with respect to qualified property or services that:. In the case of property, does not exceed the gross profit percentage of the price at which the property is offered to customers; or

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Accounting for Customer Loyalty Programs: Opportunities

Likewise, the IRS has addressed the regulation’s “redeemable . . . in merchandise, cash, or other property” requirement and concluded that, when additional consideration is required to redeem coupons (e.g., a “cents-off” coupon), a customer’s right to redeem coupons is conditioned on a future purchase, making it more appropriate to

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Customer Reward Programs: Deducting Fulfillment Costs

Regs. Sec. 1.451-4 provides a narrow exception to the economic performance rules that allows accrual-basis taxpayers who issue premium coupons (or trading stamps) to deduct the estimated fulfillment cost of the coupons (or stamps) at the time they are issued.

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IRS Issues Guidance on Treatment of Gift Cards

Rev. Proc. 2001-17 establishes a safe-harbor method of accounting for the treatment of gift cards issued to customers in exchange for returned merchandise. The revenue procedure states that—to avoid disputes about the proper characterization of gift cards issued for returned goods, provide better matching of income and costs, and

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Deducting Losses on Worthless Investment Securities

The general rule for deducting losses on worthless investment securities is found in Sec. 165(g), which permits a loss deduction for a security that becomes worthless during the tax year, but only if the security is a capital asset in the taxpayer’s hands. with interest coupons or in registered form. With respect to debt securities

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Losses Related to an Insolvent Corporation

The definition of a “security” in Sec. 165(g)(2) includes a share of stock in a corporation; a right to subscribe for, or to receive, a share of stock in a corporation; or a debt instrument issued by a corporation with interest coupons or in registered form. Sec. 165(g)(3) provides an exception for a taxpayer’s capital loss if the

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