thompson ria

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The Offshore Credit Card and Financial Arrangement Probe: Fraught With Danger for Taxpayers

Over the past two years, the services has conducted a major investigation into the use by U.S. taxpayers of payment cards issued by financial institutions in tax havens where bank secrecy laws protect the identity of the beneficial owners of the accounts. Some IRS representatives have described the offshore payment...

Tags: Offshore, Payment, Financial, Credit Card, Internal Revenue Service, Thompson RIA, Financial Accounting, Operational Accounting, Finance

White papers 2003-01-10

Applying the Unrelated Debt-Financed Income Rules to Investments in Real Property

The article focuses on the debt finance. If debt-financed real estate acquired by an exempt organization does not qualify for one of the statutory exceptions from the debt-financed property rules, it will be subject to tax unless the exempt organization is a "qualified organization." Exempt organizations can also avoid...

Tags: Investment, Income, Thompson RIA, Real Estate, Business Operations

White papers 2003-01-10

The Traps and Pitfalls of the Consolidated Duplicated Loss Rules

The IRS and TREASURY hurriedly issued temporary regulations designed to prevent a consolidated group from obtaining more than one tax benefit from a single economic loss. To carry out this purpose, Temp. Reg. 1.1502-35T (the "Temporary Regulations") contains complex rules to recompute, suspend, or permanently disallow a loss on...

Tags: Thompson RIA, Regulations, Government

White papers 2003-01-10