15) While the technical soundness of the idea can create an attractive pull, the perceived risk of making the change
can distort the pulling force.
97-27 of the change
in characterization of an item that has the effect of shifting income from one period to another as a situation that "may" constitute a change in method of accounting signals heightened IRS interest in treating recharacterizations as accounting method changes.
However, a material change in principle requires auditors to modify the standard report by referring to the change
in an explanatory paragraph.
Emergency Change - Did an approval follow the change
within a timely manner?
Field agents and appeals officers, as the IRS personnel most knowledgeable of the taxpayer's facts and circumstances, should be accorded discretion to determine whether an adjustment constitutes an accounting method and, if so, the proper manner of implementing the change
The group receiving the new modified unqualified consistency report and the group receiving the new standard unqualified report not mentioning the change
Serena Software, the Change
Governance(TM) leader, provides software and services to more than 15,000 organizations around the world -- including 96 of the Fortune 100 and 90 of the Global 100.
They need opportunities to engage in constructive dialogue about the change
, what it means for them, and how they can contribute.
In light of its holding on the merits, the district court's statements about the change
in accounting method were clearly dicta.
Is not an S corporation and does not elect this status for the year immediately following the change
in accounting period.
Governance(TM) leader, today announced the addition of Elizabeth Hackenson to its board of directors.
382(h)(6)(A), any item of income properly taken into account during the recognition period is treated as recognized built-in gain (RBIG) if the item is attributable to periods before the change
The purpose of both statutes is to limit the amount of prechange tax attributes that may be used following the change
Buchanan Ingersoll & Rooney PC served as Highmark's legal advisor and Bingham McCutchen LLP represented the majority selling stockholder in the acquisition and ECCA with respect to the Change
of Control Offer for ECCA's Notes, discussed below.
The converted property is subject to the MACRS depreciation methods, recovery periods and placed-in-service conventions applicable in the change