8/3/2019 Letter From The Managing Partner: December 2011

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8/3/2019 Letter From The Managing Partner: December 2011

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Dear Clients and Friends of SingerLewak:

Year-end tax planning is especially challenging this year because of uncertainty over whether

Congress will enact sweeping tax reform that could have a major impact in 2012 and beyond.

And even if there's no major tax legislation in the immediate future, ... [READ MORE] 

At SingerLewak, our Tax Practice group offers a wide array of tax services and expertiserelating to tax laws and subject matters. Since 2008, members of the Tax Practice group have

often contributed articles to the Tax Adviser publication.  In the November 2011 edition, eleven articles demonstrating our range of technical knowledge

at SingerLewak were published in the Tax Adviser’ s Tax Clinic section edited by our tax

partner, Mark Cook. These articles were great resources for businesses, individuals and

estates, and you can review them here: 

l THE TAX ADVI SER 

Updated Guidance on the Determination of Basis of Stock in Transferred Basic

Transactions  

By Rina Pineda, CPA, MST - Woodland Hills 

Rev. Proc. 2011-35 was issued in response to the increasing difficulty of determining the

transferred basis in stock associated with type B reorganizations as defined in Sec. 368

(a)(1)(B), particularly when the stock is publicly traded.

[READ MORE] 

International Students and the American Opportunity Tax Credit 

By Seth M. Colwell, CPA, M. Tax

Editor: Mark Cook, CPA, MBA - Irvine 

On February 17, 2009, President Barack Obama signed the American Recovery and

Reinvestment Act of 2009, P.L. 111-5, which created the American opportunity tax credit

(AOTC). 

[READ MORE]

Revisiting the New Markets Tax Credit 

By Sarah Lovinger - Irvine 

The new markets tax credit (NMTC) was enacted under the Community Renewal Tax

Relief Act of 2000, P.L. 106-554, and was incorporated into the Internal Revenue Code

as Sec. 45D. 

[READ MORE]

The Codified Economic Substance Doctrine and Related P enalties 

By David Yu - Irvine 

The IRS issued a directive on July 15, 2011, from its Large Business and International

(LB&I) Division (LB&I-4-0711-015) to help examiners and their managers determine the

appropriateness of seeking the approval of the director of field operations (DFO) whenraising the economic substance doctrine.

[READ MORE] 

Employers Immune from Suite for Complying w ith IRS Levy 

By Michael P. Mansour - Los Angeles 

When a taxpayer fails to satisfy his or her tax liabilities, the IRS has an array of 

administrative tools for obtaining taxpayers’ compliance. 

[READ MORE] 

Offers in Compromise and the Consideration of Disspated Assets  

By Andres Molgora, CPA - Los Angeles 

Since 2008, with the decline in the U.S. economy, the IRS has seen an increase inrequests for offers in compromise from financially strapped taxpayers.

[READ MORE] 

IRS Revamps Lien P rocedures to Help Struggling Taxpayers 

By Anne Chang, CPA - Irvine 

Since 2008, many taxpayers have been facing unusual financial difficulties due to the

economic downturn. As a corollary, some individuals and families have been unable to

keep current on their tax obligations. 

[READ MORE]

California Changes Combined Reporting for Assignment of Combined Group Sales  

By Jonathan E. Kraft - Los Angeles 

On May 26, 2011, California’ s Franchise Tax Board (FTB) held an interested parties

meeting to discuss possible amendments to the regulations pertaining to the

assignment of sales of tangible personal property by members of a combined reporting

group. 

[READ MORE]

California's Click-Through Nexus Law  

By Christian J. Burgos, J.D., LL.M. - Los Angeles 

On June 28, 2011, California Governor Jerry Brown signed a “click-through nexus” law

requiring out-of-state online retailers to collect sales tax on all taxable sales of tangible

personal property made through internet-based referrals (CA AB 28, Laws 2011).

[READ MORE] 

Software and California Sales and Use Tax 

By Christian J. Burgos, J.D., LL.M. - Los Angeles 

The taxability of software for sales and use tax purposes has been a point of persistent

debate among states for several years. Many states, including California, have applied

sales tax to software based on the form in which it is sold and delivered to consumers. 

[READ MORE] 

Deferral of Income from Sale of Gift Cards 

By Mark Brown - Irvine 

In recent years, retailers have experienced a significant increase in the sale of gift

cards, which have become a large percentage of total sales. 

[READ MORE] 

For additional information of resources from our Tax department, please feel free to reach out

to your Partner contact and we will assist you. 

David Krajanowski, CPA

Managing Partner