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TAX PRACTICE GROUP GETS PUBLISHED

At SingerLewak, our Tax Practice group offers a wide array of tax services and expertise
relating to tax laws and subject matters. Since 2008, members of the Tax Practice group have
often contributed articles to the Tax Advisor publication.

In the November 2010 edition, seven articles demonstrating our range of technical knowledge
at SingerLewak were published in the Tax Advisor’s Tax Clinic section edited by our tax
partner, Mark Cook. Ranging from topics such as Employee Benefits & Pensions and State &
Local Taxes to Consolidated Returns, the articles were great resources for businesses,
individuals and estates. The following were the articles from our team:

l CONSOLIDATED RETURNS
Deferral of Loss from Sale or Exchange between Members
By Todd Northrup, CPA, MBT, Tax Partner - Woodland Hills

On June 25, 2010, the IRS Office of Chief Counsel issued Chief Counsel Advice (CCA)
201025046, rejecting a parent corporation’s argument that it was entitled to take into
account a loss arising from its sale of domestic subsidiary (Sub 1) stock to a foreign
subsidiary. [READ MORE]

l EMPLOYEE BENEFITS & PENSIONS

Temp. Regs Explain New Health Plan Requirements to Provide Preventative
Services Without Cost Sharing
By Anne Y. Chang, CPA, MBA - Orange County

The Patient Protection and Affordable Care Act, P.L. 111-148 (the Affordable Care Act),
was enacted on March 23, 2010.  [READ MORE]

l EXPENSES & DEDUCTIONS

Hypothetical Independent Investor Test Tips the Scale in a Reasonable
Compensation Case
By John Eckweiler, CPA, Tax Partner -Orange County

A common focus of IRS scrutiny is the reasonableness of compensation paid by closely

held companies to owner-employees and their family members.  [READ MORE]

l GAINS & LOSSES

Sec. 121 Exclusion of Gain from Sale of a Principal Residence
By Sarah Lovinger - Orange County

For generations, citizens and residents of the United States have pursued  the American

dream of home ownership.  [READ MORE]

l PROCEDURE & ADMINISTRATION

D.C. Circuit Finds Work Product Protection Not Waived by Disclosure to Independent
Auditors
By Michael Wu, CPA, MBA, Tax Partner - Silicon Valley

On June 29, 2010, the Court of Appeals for the D.C. Circuit denied an IRS motion to
obtain from Dow Chemical Company’s independent auditor, Deloitte & Touche USA, LLP,
  three documents in connection with ongoing tax litigation between Dow and the IRS.  
[READ MORE]

District Court Rules That Same-Sex Married Couples May File Joint Returns
By Mark Brown - Orange County
A federal district court in Massachusetts recently rendered an important decision in the
continuing legal conflict over same-sex marriage.   [READ MORE]

Revised LMSB Examiner Procedures for Tax Preparer Penalty Cases  

By Michael Coley, CPA, MST – Orange County

In memorandum issued June 9, 2010, the IRS’s Large and Mid-Size Business (LMSB)
Division (now known as the Large Business and International Division) revised examiner
procedures for tax return preparer penalty cases (LMSB-4-0310-012). [READ MORE]

l STATE & LOCAL TAXES

California S.B. 974’s Impact on California Enterprise Zones
By Christian Burgos, J.D., L.L.M., - Los Angeles

The California Enterprise Zone (EZ) tax credit program was established in 1984 in an
effort to stimulate business and industrial growth in economically depressed areas of
the state.   [READ MORE]

California’s Move to Single Sales Factor

By Javier Ramirez, Tax Partner – Orange County and Christian Burgos, J.D., L.L.M., - Los
Angeles

On February 20, 2009, Governor Arnold Schwarzenegger signed budget legislation that
makes significant changes to California tax law. [READ MORE]

l TAX ACCOUNTING
Unrealized Built-in Gains and Losses Under Sec. 382 and the Tax Accounting Rules
By Andrew Gantman, CPA, MBA, MBT, Tax Partner – Woodland Hills

Many practitioners already know that Sec. 382 generally limits the use of a corporation’s
net operating losses (NOLs) in cases where there is an increase in ownership of more
than 50 percentage points by one or more 5% shareholders during a three-year testing
period. [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