Circular 230 Disclaimer & Other Disclosures

To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or tax-related matter(s) addressed herein.

This blog is personal, reflects my own views and not the views of my employer, and has not be reviewed by my employer for completeness or accuracy.

Friday, February 25, 2011

SubChapter M Tax: Tax News & Views - IRS provides transition relief ...

SubChapter M Tax: Tax News & Views - IRS provides transition relief ...: "Tax News & Views IRS provides transition relief from section 6045B reportingThe Internal Revenue Service February 22 released guidance t..."

Wednesday, February 23, 2011

SubChapter M Tax: Postponing Filing Date for Section 6045B Issuer Return - IRS Notice 2011-18

SubChapter M Tax: Postponing Filing Date for Section 6045B Issuer Return - IRS Notice 2011-18

SubChapter M Tax: Qualifying Income under 851(b)(2) from Commodity Linked Notes - IRS Private Letter Ruling 201107012

SubChapter M Tax: Qualifying Income under 851(b)(2) from Commodity Linked Notes - IRS Private Letter Ruling 201107012

SubChapter M Tax: Deloitte | Performance | Performance issue 4, January 2011

SubChapter M Tax: Deloitte | Performance | Performance issue 4, January 2011

SubChapter M Tax: World Tax Advisor - Thailand Interest Withholding

SubChapter M Tax: World Tax Advisor - Thailand Interest Withholding: "World Tax Advisor Thailand: Interest withholding tax exemption repealed for some government bonds"

SubChapter M Tax: RIC Moderatization Act

SubChapter M Tax: RIC Moderatization Act

SubChapter M Tax: Deloitte | Peru Tax Alert - 17 February 2011 | International Tax

SubChapter M Tax: Deloitte | Peru Tax Alert - 17 February 2011 | International Tax

SubChapter M Tax: Requirements for Obtaining a PTIN - IRS Notice 2011-11

SubChapter M Tax: Requirements for Obtaining a PTIN - IRS Notice 2011-11

SubChapter M Tax: Qualifying Income under 851(b)(2) from CPI Swaps -...

SubChapter M Tax: Qualifying Income under 851(b)(2) from CPI Swaps -...: "Qualifying Income under 851(b)(2) from CPI Swaps - IRS Private Letter Ruling 201106006 This responds to your request for a ruling dated Jul..."

SubChapter M Tax: Ownership of Assets Held in Variable Contract Segregated Asset Accounts - IRS Private Letter Ruling 201105012

SubChapter M Tax: Ownership of Assets Held in Variable Contract Segregated Asset Accounts - IRS Private Letter Ruling 201105012

SubChapter M Tax: REIT Change in Entity Classification & Consent to Extend Period of Limitations - IRS Private Letter Ruling 201104042

SubChapter M Tax: REIT Change in Entity Classification & Consent to Extend Period of Limitations - IRS Private Letter Ruling 201104042

SubChapter M Tax: Related Party Rent Exception from a Qualified Health Care Property of a REIT under IRC 856 - IRS Private Letter Ruling 201104033

SubChapter M Tax: Related Party Rent Exception from a Qualified Health Care Property of a REIT under IRC 856 - IRS Private Letter Ruling 201104033

SubChapter M Tax: Recognition of Cash Payments on Forward Contracts ...

SubChapter M Tax: Recognition of Cash Payments on Forward Contracts ...: "Recognition of Cash Payments on Forward Contracts - IRS Private Letter Ruling 201104031 ISSUES:1. Should the entire amount of cash paid to _..."

SubChapter M Tax: Related Party Rent Exception from a Qualified Heal...

SubChapter M Tax: Related Party Rent Exception from a Qualified Heal...: "Related Party Rent Exception from a Qualified Health Care Property of a REIT under IRC 856 - IRS Private Letter Ruling 201104023 This is in..."

SubChapter M Tax: Qualifying Income from Commodity Linked Notes & In...

SubChapter M Tax: Qualifying Income from Commodity Linked Notes & In...: "Qualifying Income from Commodity Linked Notes & Income from a CFC under 851(b)(2) - IRS Private Letter Ruling 201104013 This responds t..."

SubChapter M Tax: REIT Restructuring in an IPO - IRS Private Letter ...

SubChapter M Tax: REIT Restructuring in an IPO - IRS Private Letter ...: "REIT Restructuring in an IPO - IRS Private Letter Ruling 201104005 Pursuant to a plan, Parent intends to undertake an initial public offeri..."

SubChapter M Tax: Paid Preparer Rules & PTINs- IRS Notice 2011-6

SubChapter M Tax: Paid Preparer Rules & PTINs- IRS Notice 2011-6: "Paid Preparer Rules - IRS Notice 2011-6 Notice 2011-6 Purpose This notice provides guidance regarding the implementation of new Treasury re..."

SubChapter M Tax: Qualifying Income from Derivative Instruments - IR...

SubChapter M Tax: Qualifying Income from Derivative Instruments - IR...: "Qualifying Income from Derivative Instruments - IRS Private Letter Ruling 201103036 This responds to your request for a ruling dated Novemb..."

SubChapter M Tax: Qualifying Income from a CFC - IRS Private Letter ...

SubChapter M Tax: Qualifying Income from a CFC - IRS Private Letter ...: "Qualifying Income from a CFC - IRS Private Letter Ruling 201103033 This is in response to a letter dated August 19, 2010, requesting ruling..."

SubChapter M Tax: Qualifying Income from Commodity Linked Notes - IR...

SubChapter M Tax: Qualifying Income from Commodity Linked Notes - IR...: "Qualifying Income from Commodity Linked Notes - IRS Private Letter Ruling 201103019 This responds to the request dated May 28, 2010 submitt..."

SubChapter M Tax: Qualifying Income from a CFC - IRS Private Letter ...

SubChapter M Tax: Qualifying Income from a CFC - IRS Private Letter ...: "Qualifying Income from a CFC - IRS Private Letter Ruling 201103017 This is in response to a letter dated May 10, 2010, requesting a ruling ..."

SubChapter M Tax: Qualifying Income from a CFC - IRS Private Letter ...

SubChapter M Tax: Qualifying Income from a CFC - IRS Private Letter ...: "Qualifying Income from a CFC - IRS Private Letter Ruling 201103009 This is in response to a letter dated April 14, 2010, requesting a rulin..."

SubChapter M Tax: Consent Dividends in the Year of Liquidation - IRS...

SubChapter M Tax: Consent Dividends in the Year of Liquidation - IRS...: "Consent Dividends in the Year of Liquidation - IRS Private Letter Ruling 201103001 This is in reply to a letter dated January 20, 2010, req..."

SubChapter M Tax: Qualifying Income from a CFC and Commodity Linked ...

SubChapter M Tax: Qualifying Income from a CFC and Commodity Linked ...: "Qualifying Income from a CFC and Commodity Linked Notes - IRS Private Letter Ruling 201102055 This is in response to a letter dated July 13..."

SubChapter M Tax: Qualifying Income from a CFC - IRS Private Letter ...

SubChapter M Tax: Qualifying Income from a CFC - IRS Private Letter ...: "Qualifying Income from a CFC - IRS Private Letter Ruling 201102047 This responds to your letter dated July 9, 2010 submitted by your author..."

SubChapter M Tax: Implementation of Rules Governing Tax Return Prepa...

SubChapter M Tax: Implementation of Rules Governing Tax Return Prepa...: "Implementation of Rules Governing Tax Return Preparers Notice 2011-6 Purpose This notice provides guidance regarding the implementation of ..."

SubChapter M Tax: ICI - IRS Exempts from PTIN Rules Certain Forms Re...

SubChapter M Tax: ICI - IRS Exempts from PTIN Rules Certain Forms Re...: "ICI - IRS Exempts from PTIN Rules Certain Forms Related to Retirement Plans: 24831 January 5, 2011 RE: IRS EXEMPTS FROM PTIN RULES CERTAIN ..."

SubChapter M Tax: ICI - IDC Files Comment Letter on PWG Report On Mo...

SubChapter M Tax: ICI - IDC Files Comment Letter on PWG Report On Mo...: "ICI - IDC Files Comment Letter on PWG Report On Money Market Fund Reform Options: [24849] January 10, 2011 RE: IDC FILES COMMENT LETTER ON ..."

SubChapter M Tax: ICI - ICI Launches Cost Basis Reporting Member Res...

SubChapter M Tax: ICI - ICI Launches Cost Basis Reporting Member Res...: "ICI - ICI Launches Cost Basis Reporting Member Resource Web Page: [24863] January 11, 2011 RE: ICI LAUNCHES COST BASIS REPORTING MEMBER RES..."

SubChapter M Tax: ICI - ICI Letter to IRS and Treasury on Average Co...

SubChapter M Tax: ICI - ICI Letter to IRS and Treasury on Average Co...: "ICI - ICI Letter to IRS and Treasury on Average Cost as Default Method: [24877] January 14, 2011 RE: ICI LETTER TO IRS AND TREASURY ON AVER..."

SubChapter M Tax: ICI - ICI Launches Derivatives Markets Advisory Co...

SubChapter M Tax: ICI - ICI Launches Derivatives Markets Advisory Co...: "ICI - ICI Launches Derivatives Markets Advisory Committee: 24893 January 20, 2011 The Institute has formed a new advisory committee, the “..."

SubChapter M Tax: Financial Reform—What It Means for CPAs

SubChapter M Tax: Financial Reform—What It Means for CPAs: "Financial Reform—What It Means for CPAs: 'Financial Reform—What It Means for CPAs In the wake of the economic crisis in 2008, policymakers ..."

SubChapter M Tax: IRS Exempts CPA-Supervised Nonsigners From New Pre...

SubChapter M Tax: IRS Exempts CPA-Supervised Nonsigners From New Pre...: "IRS Exempts CPA-Supervised Nonsigners From New Preparer Rules: 'IRS Exempts CPA-Supervised Nonsigners From New Preparer Rules DECEMBER 30, ..."

SubChapter M Tax: A Primer on New Tax-Reporting Rules for Funds, ETF...

SubChapter M Tax: A Primer on New Tax-Reporting Rules for Funds, ETF...: "A Primer on New Tax-Reporting Rules for Funds, ETFs - WSJ.com: 'TAX SMARTS New Tax Reporting Rules The IRS will get more information about..."

SubChapter M Tax: Tax News & Views - S corps, RICs, REITs eligible f...

SubChapter M Tax: Tax News & Views - S corps, RICs, REITs eligible f...: "Tax News & Views S corps, RICs, REITs eligible for five-year built-in gains recognition period for 2011 transactions The start of the ..."

SubChapter M Tax: Tax News & Views - S corps, RICs, REITs eligible f...

SubChapter M Tax: Tax News & Views - S corps, RICs, REITs eligible f...: "Tax News & Views S corps, RICs, REITs eligible for five-year built-in gains recognition period for 2011 transactions The start of the ..."

SubChapter M Tax: Deloitte | Uncertain tax positions | IRS Announcem...

SubChapter M Tax: Deloitte | Uncertain tax positions | IRS Announcem...: "Deloitte | Uncertain tax positions | IRS Announcement 2010-9 | Tax risk | Tax transparency | Tax governance | Tax compliance: 'The IRS’s Fi..."

SubChapter M Tax: ICI - ICI Letter On CFTC Proposal Restricting Inve...

SubChapter M Tax: ICI - ICI Letter On CFTC Proposal Restricting Inve...: "ICI - ICI Letter On CFTC Proposal Restricting Investments Of Customer Funds In Money Market Funds: As we previously indicated, the Commodit..."

SubChapter M Tax: Deloitte | IFRS | Select Tax Considerations | CFO ...

SubChapter M Tax: Deloitte | IFRS | Select Tax Considerations | CFO ...: "Deloitte | IFRS | Select Tax Considerations | CFO Insights | CFO Center | Chief Financial Officer: 'Accounting standards worldwide are incre..."

SubChapter M Tax: Private Letter Rulings, Technical Advice Memoranda...

SubChapter M Tax: Private Letter Rulings, Technical Advice Memoranda...: "Private Letter Rulings, Technical Advice Memoranda and Field Service Advice Memoranda involving Tax Exempt Bond Issues"

SubChapter M Tax: ICI - ICI Submits Supplemental Economic Analysis o...

SubChapter M Tax: ICI - ICI Submits Supplemental Economic Analysis o...: "ICI - ICI Submits Supplemental Economic Analysis on the SEC Proposal to Replace Rule 12b-1 With a New Distribution Framework: As you know, ..."

SubChapter M Tax: ICI - ICI Comment Letter on Treasury Determination...

SubChapter M Tax: ICI - ICI Comment Letter on Treasury Determination...: "ICI - ICI Comment Letter on Treasury Determination Regarding Status of FX Swaps and Forwards as 'Swaps': 'RE: ICI COMMENT LETTER ON TREASURY..."

SubChapter M Tax: ICI - PFIC Survey Discontinued at Tax Committee's ...

SubChapter M Tax: ICI - PFIC Survey Discontinued at Tax Committee's ...: "ICI - PFIC Survey Discontinued at Tax Committee's Direction: 'TO: ACCOUNTING/TREASURERS MEMBERS No. 38-10 CLOSED-END INVESTMENT COMPANY MEM..."

SubChapter M Tax: Deloitte | Heads Up: Repo 101 — FASB Gets Back to ...

SubChapter M Tax: Deloitte | Heads Up: Repo 101 — FASB Gets Back to ...: "Deloitte | Heads Up: Repo 101 — FASB Gets Back to Basics on Repurchase Accounting:"

SubChapter M Tax: Deloitte | Heads Up: Constituents Share Views on t...

SubChapter M Tax: Deloitte | Heads Up: Constituents Share Views on t...: "Deloitte | Heads Up: Constituents Share Views on the FASB's AFI Project:"

SubChapter M Tax: Deloitte | Heads Up: SEC Issues First Progress Rep...

SubChapter M Tax: Deloitte | Heads Up: SEC Issues First Progress Rep...: "Deloitte | Heads Up: SEC Issues First Progress Report on Consideration of Incorporating IFRSs Into U.S. System:"

SubChapter M Tax: Drinker Biddle - Publications - RIC Tax Measures E...

SubChapter M Tax: Drinker Biddle - Publications - RIC Tax Measures E...: "Drinker Biddle - Publications - RIC Tax Measures Enacted: '12/23/2010 RIC Tax Measures Enacted Investment Management Alert Stephen Hamilton,..."

SubChapter M Tax: Deloitte | RIC Modernization Act 2010 | Private Eq...

SubChapter M Tax: Deloitte | RIC Modernization Act 2010 | Private Eq...: "Deloitte | RIC Modernization Act 2010 | Private Equity, Hedge Funds, and Mutual Funds: 'Regulated Investment Company Modernization Act of 2..."

SubChapter M Tax: Deloitte | RIC Modernization Act 2010 | Private Eq...

SubChapter M Tax: Deloitte | RIC Modernization Act 2010 | Private Eq...: "Deloitte | RIC Modernization Act 2010 | Private Equity, Hedge Funds, and Mutual Funds: 'Regulated Investment Company Modernization Act of 2..."

SubChapter M Tax: A first look at the Regulated Investment Company M...

SubChapter M Tax: A first look at the Regulated Investment Company M...: "A first look at the Regulated Investment Company Modernization Act of 2010"

SubChapter M Tax: Bill Text - 111th Congress (2009-2010) - THOMAS (L...

SubChapter M Tax: Bill Text - 111th Congress (2009-2010) - THOMAS (L...: "Bill Text - 111th Congress (2009-2010) - THOMAS (Library of Congress): 'Regulated Investment Company Modernization Act of 2010 (Enrolled B..."

SubChapter M Tax: ICI - Legislation Enacted to Extend Tax Provisions...

SubChapter M Tax: ICI - Legislation Enacted to Extend Tax Provisions...: "ICI - Legislation Enacted to Extend Tax Provisions Benefiting Fund Shareholders: '[24800] We are very pleased to inform you that legislati..."

SubChapter M Tax: Provisions in the Senate’s Tax Cut Extension Bill

SubChapter M Tax: Provisions in the Senate’s Tax Cut Extension Bill: "Provisions in the Senate’s Tax Cut Extension Bill: 'Provisions in the Senate's Tax Cut Extension Bill DECEMBER 10, 2010 Senate Majority Le..."

SubChapter M Tax: ICI - District Court Rules for Defendants in Exces...

SubChapter M Tax: ICI - District Court Rules for Defendants in Exces...: "ICI - District Court Rules for Defendants in Excessive Fee Case: A District Court in Minnesota has granted summary judgment for the defenda..."

SubChapter M Tax: Gallus Case First to Apply the Jones Decision

SubChapter M Tax: Gallus Case First to Apply the Jones Decision: "Investment Management Alert | December 10, 2010 Gallus Case First to Apply the Jones Decision The United States Distric..."

SubChapter M Tax: ICI - 2010 ICI State Tax Surveys

SubChapter M Tax: ICI - 2010 ICI State Tax Surveys: "ICI - 2010 ICI State Tax Surveys: The Institute’s 2010 surveys on state tax matters are now available on the Institute’s website. The..."

SubChapter M Tax: ICI - CFTC and SEC Jointly Propose Definitions for...

SubChapter M Tax: ICI - CFTC and SEC Jointly Propose Definitions for...: "ICI - CFTC and SEC Jointly Propose Definitions for 'Swap Dealer' and 'Major Swap Participant': The Securities and Exchange Commission and t..."

SubChapter M Tax: Consent Dividends under IRC 565(a) - IRS Private L...

SubChapter M Tax: Consent Dividends under IRC 565(a) - IRS Private L...: "Consent Dividends under IRC 565(a) - IRS Private Letter Ruling 201049004 This letter is in response to a ruling request dated February 18, ..."

SubChapter M Tax: Qualifying Income from a Wholly Owned Subsidiary -...

SubChapter M Tax: Qualifying Income from a Wholly Owned Subsidiary -...: "Qualifying Income from a Wholly Owned Subsidiary - IRS Private Letter Ruling 201051014 This responds to your letter dated May 10, 2010, sub..."

SubChapter M Tax: Tax Alert Electing use of the mark-to-market meth...

SubChapter M Tax: Tax Alert Electing use of the mark-to-market meth...: "Tax Alert Electing use of the mark-to-market method of accounting under section 475(f) In Private Letter Ruling 201043030 (the 'PLR')..."

SubChapter M Tax: Tax treatment of a cash-settled option contract to...

SubChapter M Tax: Tax treatment of a cash-settled option contract to...: "Tax Alert Tax treatment of a cash-settled option contract to purchase a basket of securities In a recent Generic Legal Advice Memora..."

SubChapter M Tax: qualifying income under 851(b)(2) from a Controlle...

SubChapter M Tax: qualifying income under 851(b)(2) from a Controlle...: "qualifying income under 851(b)(2) from a Controlled Foreign Corp - IRS Private Letter Ruling 201049015 This responds to your letter dated Ap..."

SubChapter M Tax: Qualifying income under 851(b)(2) from a Controlle...

SubChapter M Tax: Qualifying income under 851(b)(2) from a Controlle...: "Qualifying income under 851(b)(2) from a Controlled Foreign Corp - IRS Private Letter Ruling 201048021 This is in response to your letter ..."

SubChapter M Tax: qualifying income under 851(b)(2) from a Controlled Foreign Corp - IRS Private Letter Ruling 201048022

SubChapter M Tax: qualifying income under 851(b)(2) from a Controlled Foreign Corp - IRS Private Letter Ruling 201048022
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