Corporate Tax Planning
100 episodes - English - Latest episode: almost 4 years ago - ★★★★★ - 1 ratingCovers C (regular) corporate taxation and planning including taxation of shareholders
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Episodes
Video Podcast: Keebler and Shenkman on the PPP Flexibility Act
June 05, 2020 00:27In this 12-minute video podcast, Bob Keebler and Marty Shenkman discuss the Paycheck Protection Program Flexibility Act, passed by both houses of Congress and expected to be signed by the President. Recorded June 4, 2020. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler on Notice 2019-07
January 25, 2019 01:02 - 8.87 MBWhen does the rental of real estate constitute a trade or business for purposes of Code section 199A? Bob Keebler analyzes Notice 2019-07 in this 10-minute podcast. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler -- Overview of the Section 199A Proposed Regulations
August 17, 2018 04:37 - 12.8 MBIn this 14-minute podcast, Bob Keebler provides an overview of the proposed regulations implementing the income tax deduction for qualified business income. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Tax Planning for Real Estate Under TCJA
March 16, 2018 22:05 - 18.4 MBIn this 20-minute podcast, Bob Keebler discusses income tax planning for real estate investors under the Tax Cuts and Jobs Act, including the new Code section 199A deduction. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Tax Reform Under President Trump
January 01, 2017 20:29 - 1.59 MBBob Keebler and Jonathan Blattmachr This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Keebler and Angkatavanich on Section 2701 Basics
October 29, 2015 02:58 - 1.95 MBIn this podcast, Bob Keebler and Todd Angkatavanich discuss the basics of Internal Revenue Code section 2701, including: - How section 2701 relates to the rest of Chapter 14 - Application of the section to a broad scope of transactions - The "vertical slice" rule - Recapitalizations and CCA 201442053 - Planning opportunities. Recorded August 25, 2015. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and ...
American Taxpayer Relief Act of 2012
January 08, 2013 22:04 - 44.7 KBEstate Planning after the American Taxpayer Relief Act of 2012 Video Presentation. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Keebler and Shenkman: Planning
October 12, 2012 22:42 - 4.63 MBBob Keebler and Marty Shenkman discuss planning between now and December 31st. The time is crucial and the opportunity is not to be missed. Marty has created a postcard to inform clients of 2012 planning opportunities. A company called "Printing for Less" - which does Marty's newsletter - will customize and mail it for any practitioner at a 20% discount off printing costs + postage. (Marty gets no payment from this). You can use his postcard primarily with no royalties (but a nice not...
Keebler - Covered Opinion Rules
September 18, 2012 06:51 - 1.47 MBBob interviews attorney Michael Goller who discusses the new Covered Opinion Proposed Regulations. This is a very important development focusing on Section 10.37 - dealing with tax opinions and how attorneys must comply. Also stressed in this interview is section 10.35, which requires competence and 10.36 dealing with management oversight proceedures and standards. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our soft...
Keebler - Taxpayer Penalties
March 25, 2012 20:48 - 2.85 MBBob speaks with Mike Gollar, a tax attorney about Taxpayer Penalties and how to avoid them. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Keebler and Blattmachr - Planning in 2012
January 31, 2012 02:12 - 3.63 MBStars Bob Keebler and Jonathan Blattmachr discuss multiple planning tactics and considerations for this most important and pivotal year. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Keebler - Strategies for Mitigating Taxation of Concentrated Low Basis Positions
September 26, 2011 04:53 - 1.96 MBHow can a client reduce the potential tax burden where the holding in question is a large concentration of stock in one or two companies? Bob Keebler discusses Strategies for Mitigating taxation of concentrated low basis positions. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Paul Hood - Noncontrolling Normalizing Adjustments
September 14, 2011 07:27 - 3.16 MBPaul Hood discusses non-controlling normalizing adjustments. Don't miss Paul's upcoming 9/28 program at 12:00 P.M. EDT talk on Phil Cavesh?s Ultimate Estate Planner. It's A Method in the Madness: The Fine Art of Designing Estate Planning Tools and Techniques. To learn more or sign up: http://www.ultimateestateplanner.com/092811PH.html This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Prese...
Paul Hood - S Corporation Tax Affecting
September 12, 2011 22:10 - 2.72 MBPaul Hood - Tax Affect or not Tax Affect S Corporation earnings? Paul Hood discusses the issues. Is there a premium? Should you believe the Tax Court? Keep listening. Paul Hood will be hosting a 90 minute teleconference on September 28th titled ?A Method in the Madness: The Fine Art of Designing Estate Planning Tools and Techniques.? On this special teleconference, Paul will cover how proper plan design is really a 3-part analysis (the technique, the particular assets and the ?playe...
Paul Hood - Discounts for Lack of Marketability When Controlling Interest Involved
September 11, 2011 07:03 - 3.07 MBBusiness Valuation authority Paul Hood discusses valuation when a controlling interest in a closely-held corporation is involved. Paul is the co-author of a new book on business valuation - A Reviewer's Handbook to Business Valuation - that was the subject of our recent book review in Business Entities Newsletter # 127. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations si...
Paul Hood - Discounts for Built-In Capital Gains
September 10, 2011 23:32 - 3.08 MBPaul Hood, co-author with Tim Lee of the recently published book, A Reviewer's Guide to Business Valuations, discusses recent cases involving valuation discounts for built-in capital gains. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler and the Section 1022/AMT Election 'Curveball'
August 29, 2011 21:26 - 1.8 MBIn this important PodCast, Bob Keebler reviews what he is calling the Section 1022 Election/AMT 'Curveball.' According to Bob, it appears that there is a strong possibility that taxpayers electing carryover basis will have different basis for AMT and regular tax purposes. This, according to Bob, appears to have been missed by the tax writing committees and the IRS. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our softwar...
Tax Planning Opportunities in Volatile Economic Environments
August 22, 2011 03:37 - 3.51 MBIn this PodCast, Bob Keebler reviews a variety of strategies that can immediately help clients with their stock and bond investments. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler discusses Revenue Procedure 2011-41
August 10, 2011 06:55 - 1.8 MBBob Keebler discusses Revenue Procedure 2011-41, which was issued by the IRS on August 5th. Bob covers the safe harbor rules applicable when executors elect out of paying estate tax, as well as the rules on how-to allocate basis This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Bob Keebler focuses on Notice 2011-66
August 10, 2011 06:52 - 1.8 MBIn this PodCast, Bob Keebler focuses on Notice 2011-66, the 1022 election not to pay estate tax, along with impact of Form 8939 This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Budget Control Act of 2011 Part 2 of 2
August 10, 2011 06:44 - 1.8 MBIn this PodCast, Bob Keebler focuses on the tax issues raised by the Budget Control Act of 2011, along with what Congress might do in in the future. Bob also reviews the things advisors should be doing to help their clients. This is Part 2 of 2 This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Budget Control Act of 2011. This is Part 1 of 2
August 10, 2011 06:30 - 2.36 MBIn this PodCast, Bob Keebler reviewd the current fiscal situation and important dates contained in the Budget Control Act of 2011. This is Part 1 of 2 This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Paul Hood - 6 Questions Reviewers of Business Valuation Need to Ask - Part I
August 03, 2011 00:44 - 7.71 MBPaul Hood recently co-authored a new book with Tim Lee titled: A Reviewer?s Handbook to Business Valuation: Practical Guidance to the Use and Abuse of a Business Appraisal (Wiley 2011). The book is available for order on their website: http://www.bvreviewershandbook.com . Paul and Tim will be hosting a webinar on August 11, 2011 (10:00am ? 11:40am PT, 1pm-2:40pm ET) for BV Resources on reviewing business appraisals. Their webinar qualifies for 2 CE credits. Additional information on the...
Paul Hood - 6 Questions Reviewers of Business Valuation Need to Ask - Part 2
July 30, 2011 01:35 - 21.2 MBPaul recently co-authored a new book with Tim Lee titled: A Reviewer?s Handbook to Business Valuation: Practical Guidance to the Use and Abuse of a Business Appraisal (Wiley 2011). The book is available for order on their website: http://www.bvreviewershandbook.com . Paul and Tim will be hosting a webinar on August 11, 2011 (10:00am ? 11:40am PT, 1pm-2:40pm ET) for BV Resources on reviewing business appraisals. Their webinar qualifies for 2 CE credits. Additional information on their web...
Keebler - Stock Options in an Increasing Rate Environment - Part II
July 13, 2011 06:05 - 1.91 MBBob Keebler discusses important factors to consider when a client owns or is considering the use of stock options during a time when rates are increasing. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Estate Tax Law Goes to President for Signature
December 17, 2010 07:46 - 4.87 MBBob Keebler provides LISI members with a "hot off the press" PodCast on the new tax law that was passed late at night December 16, 2010. Here's info on how you can learn more on the tax law from Bob and his associates: Learn the latest on the Estate Tax Bill during Keebler Associates 90 minute teleconference next week - Monday, the 20th. Resolution of the Estate Tax - An Update on the "Final" Estate Tax Bill 2010 Choices - Urgent Decisions are Required The GST Quagmire with repeal of EGT...
Keebler - Planning Between Now and Dec 31
December 15, 2010 01:26 - 4.87 MBBob Keebler keeps LISI members ahead of the new tax law curve with this incredibly timely PodCast. Here's info on how you can learn more from Bob and his associates: Learn the latest on the Estate Tax Bill during Keebler Associates 90 minute teleconference next week - Monday, the 20th. Resolution of the Estate Tax - An Update on the "Final" Estate Tax Bill 2010 Choices - Urgent Decisions are Required The GST Quagmire with repeal of EGTRRA $5 Million Gift Tax Exemption $5 Million GST Exempt...
What's Up Doc? Employee or Not? - Ed Zollars
April 25, 2009 03:56 - 17.4 MBThis PocCast is about the definition of an employee. We look at the matter in the case of Maimon v. Commissioner, TC Summary Opinion 2009-53. Dr. Maimon attempted to argue that he was not an employee of the professional corporation he worked in (and owned some shares in), but rather was an independent contractor. He was interested in holding this position because he had ended up personally paying over legal fees and, ultimately, a $1 million settlement, in a case involving his medical ...
It's a Matter of Trust Funds - the Responsible Person Penalty - Ed Zollars
February 22, 2009 00:03 - 38.2 MBThis PodCast concerns a case dealing with the trust fund recovery penalty under "6672. In the case of Richard A. Smith v. United States, 2009 TNT 30-6, CA10, (http://ca10.washburnlaw.edu/cases/2009/02/07-4210.pdf) the Tenth Circuit refused to overturn the holding in the US District Court of Utah that Mr. Smith was a responsible person, even though he had no ownership interest in the entity in question. The case highlights the dangers for employees in accounting functions when the org...
Losses and Choices-Stimulus Bill Net Operating Loss Rules - Ed Zollars
February 16, 2009 04:58 - 24.7 MBThis PodCast is about the American Recovery Reinvestment Act of 2009. It has a number of tax provisions, and this podcast looks at the small business net operating loss provisions of the Act. This provision will require action for some taxpayers within 60 days after the bill is signed into law, as well as giving us a "sliding" window for when we start using a net operating loss for the year we elect to have it apply to. The podcast materials are located at http://www.edzollars.com/2009-02...
Closing the Open Door-S Corporation Debt - Ed Zollars
October 28, 2008 01:45 - 12.2 MBThis Podcast concerns the final regulations on S Corporation open account debt that will change the way that many clients have to deal with their loans to the corporation. These changes are effective immediately, so we have to understand how these rules work. The materials are available at http://www.edzollars.com/2008-10-31_S_OpenAccount.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and Po...
We Just Disagree-What is the Meaning of In Connection With? - Ed Zollars
September 15, 2008 06:03 - 13.5 MBThis PodCast examines a difference in application of IRC "162(k) between the Ninth Circuit Court of Appeals and the United States Tax Court given the Tax Court's decision in Ralston Purina v. Commissioner, 131 TC No. 4 that dealt with the taxpayer's attempt to claim a deduction for dividends paid to participants in its ESOP when it had to redeem certain stock from the ESOP to pay out terminated participants in that plan. The materials can be downloaded from http://www.edzollars.com/2008...
Delayed Rebate-Tax Status of Accrued Rebates - Ed Zollars
August 31, 2008 01:43 - 11.4 MBThis PodCast pertains to a common accounting issue, the differences between tax and GAAP treatment of items. Here, we focus on a case involving the time for recognizing an expense. The matter involved rebates and we look at a Chief Counsel Memorandum (ILM 200834019) outlining the IRS's view on why the taxpayer in this case could not recognize the expense related to rebates at the time a sale was made. Materials for this week's podcast can be downloaded at http://www.edzollars.com/2008-09...
Authoritative Support-Getting the Required Support for a Tax Position - Ed Zollars
August 25, 2008 04:10 - 26.7 MBThis PodCast reviews the requirements found in the regulations for obtaining the required support for a tax position, concentrating on the methods outlined in Reg. "1.6662-4(d) in the definition of "substantial authority" which are cross referenced multiple times when considering other levels of authority. The materials can be downloaded from http://www.edzollars.com/2008-08-25_Penalty.pdf . . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices....
I Wish That Hadn't Worked--Section 83(b) Election Regret - Ed Zollars
August 03, 2008 05:21 - 13 MBThis podcast is the sequel to a November 2006 podcast on the same case--that of Kadillak v. Commissioner where an individual who was caught by the "dot bomb" crash of the technology stock of his former employer attempted to mitigate the damage caused by his ISO exercise and 83(b) election made at the height of the craze. A year later, Mr. Kadillak was no longer employed by the organization, the stock price had tanked, and when he sold the stock that he didn't have to surrender got stuck wit...
Home Run-A Look at Some Tax Provisions in the New Housing Law - Ed Zollars
July 27, 2008 01:40 - 23.8 MBThis PodCast examines the American Home Rescue and Foreclosure Prevention Act of 2008, taking a detailed look at a few tax provisions in that bill of interest. We look at the refundable first time homeowners credit, the property tax deduction for nonitemizers and the soon to start restrictions on the ability to get a full Section 121 exclusion if a property has not always been used as a principal residence that will apply to usage after January 1, 2009. Watch for the required IRS guidance ...
Getting Started Automatically - IRS Modifies Rules for Start Up and Organization Costs - Ed Zollars
July 13, 2008 02:20 - 16.7 MBThis Podcast is about temporary regulations that deal with start-up and corporate and partnership organization costs. Interestingly enough, the new regulations now create an automatic election to expense/amortize all such costs, and treat problems related to the identification of costs or the proper year to begin amortization as accounting method issues. The materials are located online at http://www.edzollars.com/2008-07-14_Section_195.pdf . This Podcast is sponsored by Leimberg Informat...
IRS Releases New FAQ on HSAs - Ed Zollars
June 29, 2008 05:58 - 25.8 MBThis Podcast pertains to HSA Accounts. The IRS has issued guidance in the form of a series of questions and answers related to Health Savings Account in Notice 2008-59. This podcast covers some of the planning and design opportunities available under this Notice. Written materials for this podcast can be downloaded from http://www.edzollars.com/2008-06-30_HSA_Guidance.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit...
Proposed Regulations for Preparer Penalties - Part Two - Ed Zollars
June 26, 2008 04:37 - 25.6 MBThis PodCast is part two of a series on the proposed regulations for preparer penalties. . The materials are at http://edzollars.com/2008-06-23_Penalty.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
Proposed Regulations for Preparer Penalties - Part One - Ed Zollars
June 22, 2008 06:05 - 29.3 MBThis PodCast is the first of what will be a series of two on the proposed regulations for preparer penalties. Considering the length of the regulations and podcast, the first hour is in this file to listen to and digest, with part two to be posted later. The materials are at http://edzollars.com/2008-06-23_Penalty.pdf . . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations sit...
Who is Knocking at Your Door? Computer Security for Financial Professionals - Ed Zollars
June 15, 2008 06:01 - 29.1 MBThis PodCast is about securing client data, the responsibility of all of financial services practitioners. A presentation by Ed Zollars at the Arizona Society of CPA's Financial Planning Conference serves as the basis for this podcast. The slides used for this presentation are available at http://www.edzollars.com/2008-06-16_Knocking.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint P...
The Mailbox Rule Comes Up Once Again - Ed Zollars
April 20, 2008 03:26 - 12.6 MBThis PodCast concerns the issue of whether "7502(c) provides the exclusive means to prove timely filing of a document by a taxpayer. What the Third Circuit had to say, the IRS didn't like hearing. In the case of Philadelphia Marine Trade Ass'n.-Int'l Longshoremen's Association Pension Fund et al. v. Commissioner, 2008 TNT 74-16 the Third Circuit held that the reports of the death of the common law mailbox rule were, in the words of Mark Twain, greatly exaggerated. That places the Third Cir...
Was it a Gift or Compensation? The Tax Court Knows - Ed Zollars
April 15, 2008 20:55 - 13.3 MBThis PodCast pertains to the distinction between compensation income and gifts. Specifically, the issue is, Is a payment to a person taxable compensation income or a non-taxable (for income tax purposes) gift. The case in question is the case of Larsen v. Commissioner, TC Memo 2008-73. The materials for the podcast are at http://www.edzollars.com/2008-04-16_Gift_Comp.pdf. We also briefly discuss an interesting episode of a podcast I found on small service business operating issues at a pl...
CPA Says Error, IRS Says Accounting Method - Ed Zollars
March 16, 2008 05:58 - 10.6 MBThis PodCast is about the difference between an error and an accounting method. The question of whether a problem on a return was an error or a method of accounting is important. We'll look at the Sixth Circuit's ruling in the case of Huffman v. Commissioner, where the appeals court sustained the 20006 ruling of the Tax Court (126 TC 322) that the CPA's consistent flawed attempt to calculate inventory as prescribed by the regulations for the dollar-value, link-chain LIFO method. The reso...
Risky Business - LLC Debt Restoration Provision Fails to Provide At Risk Status - Ed Zollars
March 09, 2008 05:12 - 10.2 MBThis PodCast examines an LLC debt restoration provision. We look at the Tax Court's second pass at the case of Hubert v. Commissioner, TC Memo 2008-46, a case sent back to the Tax Court by the Sixth Circuit Court of Appeals to decide if the LLC debt restoration provision made the taxpayer the payer of last resort under the Sixth Circuit's test. The Tax Court comes back saying "No". The materials can be found at http://www.edzollars.com/2008-03-10_Risky_Business.pdf . This Podcast is spon...
Not Quite Good Enough-Timely Filing One More Time - Ed Zollars
February 24, 2008 04:26 - 10.4 MBThis PodCast pertains to the issue of "timely filing", revisiting an issue last covered in a podcast back in October of 2005. This time we look at the Tenth Circuit's opinion in the case of Gibson v. Commissioner, a case that illustrates how a taxpayer who thought he was complying with the requirements to prove a timely filing of his Tax Court petition managed to find a way to not get the benefit he thought he had. The materials are available at http://www.edzollars.com/2008-02-25_Timely_F...
Economic Stimulus Package of 2008 (Tax Matters) - Ed Zollars
February 09, 2008 04:48 - 13 MBThis PodCast is about the Economic Stimulus Package of 2008. It makes a few, but significant, tax law changes for 2008. This podcast talks about what Congress did and what we need to do about it. Materials are available at http://www.edzollars.com/2008-02-09_Economic_Stimulus.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com
So You Want Your LLC to Be An S Corporation - Ed Zollars
February 05, 2008 02:55 - 21.2 MBThis PodCast focuses on issues involved with LLCs and S corporations. This topic cuts across what is often covered in partnership discussions (the use of LLCs) and S corporations (where often LLCs are presented as an alternative to, rather than a potential form of, an S corporation). The podcast covers issues that arise when a single member LLC is used to hold S corporation stock, as well as when an LLC elects corporate status and wishes to be taxed under the S corporation rules. The mater...
Consenting to Disclosure or Use of Return Information - Ed Zollars
January 21, 2008 02:05 - 20.4 MBThis PodCast concerns Revenue Procedure 2008-12 and final regulations under "7216, both of which deal with taxpayer authorizations for the use or disclosure of tax return information by tax preparers. The regulations contain a number of new requirements that will be imposed on tax preparers, and the Revenue Procedure contains specific language that must be used for taxpayers who are filing the Form 1040 series of forms. These new requirements will take effect on January 1, 2009. The writt...
IRS's New View on 6694 and 6695 - Ed Zollars
January 01, 2008 04:16 - 15.9 MBThis PodCast concerns guidance for Preparers of tax returns. The IRS celebrated the end of 2007 by releasing three Notices late on December 31 that provide guidance on the application of the revised preparer penalties contained in the Small Business and Work Opportunity Tax Act of 2007 that was passed last May. The IRS had previously released interim relief in Notice 2007-54, but that relief was set to expire as 2007 did. The centerpiece of this guidance is Notice 2008-13, which provides i...