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Tax Returns, Examinations & IRS Procedure

This library contains hundreds of high-quality technical tax memoranda on a wide variety of topics. The memoranda are organized by topics and are fully word-searchable. This library is a rich resource of already-solved tax problems. Use it as a starting point for your own research.

The Tax Resource Group Memo Library Category: Compensation & Employee Benefits Affiliated Service Groups; Sharing of Payroll Costs; IRC: 414(m). Common Paymaster Rules; Requirements of Common Paymaster Rules; IRC: 3121(s). Corporate Officer--Employee vs. Independent Contractor; Amounts Paid to Mexican National; IRC 3121(d)(1), 3306(i), and 3401(c). Deductions for Compensation and Employment Taxes; Effects of Failure to Remit Employment Taxes on Employer's Deductions; IRC: 162, 461. Deferred Compensation; Nonqualified Deferred Compensation for Shareholders; IRC 162, 404. Deferred Compensation; Withholding on Deferred Compensation; IRC: 3121(v) and 3306(r)(2). Dependent Care Assistance; Dependent Care Assistance, 25% Rule; IRC 129(d)(4). Dependent Care Assistance; Exclusion if Both Spouses Are Covered by Separate Employers; IRC 129. Disability Insurance Plan; Excludability from Employee's Income and Deductibility by Corporation; IRC: 106, 162(a). Disability Insurance Plan; Tax Effects of Plan for Shareholders/Employees; IRC: 106. Employee Leasing; Employee Leasing to Achieve C Corporation Employee Benefits for Non-C Corporation Employers; IRC: 414(n), 401(a), 408(k). Expenses Allowable Against FICA Taxable Income; Statutory Employees; IRC 3121. FICA Tax; FICA Liability for Disability Payments; IRC: 3121(a)(4). FICA Tax; FICA Taxes in Connection with FLSA Award; IRC: 3121. FICA Tax; Mexican National; IRC 3121. Formation; Stock for Services; IRC: 83. Fringe Benefits, Company Auto; Employer and Employee Treatment of Company Car; IRC 61, 132. Health Insurance for Self-Employed Persons; Effect of Hiring Proprietor's Spouse; IRC: 105, 162. Incentive Stock Options; General Issues; IRC: 422(b)(1), 83. Income; Taxation of Social Security Disability Benefits; IRC: 86. Individual Retirement Account; Domestic Requirement; IRC: 408(a); 7701(a)(9); 72(t). Individual Retirement Account; IRA for Infant; IRC 408. Individual Retirement Account; IRA Investment Advisory Fees, Deductibility of; IRC: 212. Individual Retirement Account; Minimum Distribution Requirements, Post Mortem; IRC: 408, 401. Individual Retirement Account (Roth); Rollovers to Roth IRA; IRC 408A. Individual Retirement Account Withdrawal; Applicability of Section 72(t) to Distributions from IRA Rolled Over from Qualified Plan on Death of Participant; IRC: 72(t). Partners as Employees; Discussion of Ineligibility of Partners to Also be Employees; IRC: 707. Qualified Domestic Relations Order (QDRO); Section 72(t) Penalty on QDRO Distributions; IRC: 72(t). Qualified Plan Distributions, Withholding Requirements; Withholding on QDRO Payments; IRC 3405. Qualified Retirement Plans; 10-Year Averaging; IRC: 401. Reasonable Compensation; Accumulated Earnings Tax Issue; IRC: 162, 531. Redemptions, Complete Termination of Interest; Installment Note and Security Features as Continuing Interest; IRC: 302(b)(3), 302(c)(2), 318. Retirement Distributions; Early Withdrawal from a Qualified Pension Plan; IRC: 402(d), 72(t), 404(k). S Corporation; S Corporation Reasonable Compensation Requirement; IRC: 3121. Self-Employment Tax; Nonresident Alien; IRC 1402(b). Self-Employment Tax; SEP; Director Fees; IRC: 1402, 408(k)(7)(B). Self-Employment Tax; SEP; Insurance Commissions; IRC: 1402, 408(k)(7)(B). SEP; SEP for Statutory Employee; IRC: 3121(d)(3), 415(c). SEP; SEP's for Older Taxpayers; IRC: 408(k), 219. SEP; SEP Contributions: Eligible Earnings; IRC: 414(c), 408. SEP; Timing of Deductions when SEP Year Differs from Employer's; IRC: 404(h)(1)(A). SEP Contributions; SEP Contribution Limits when Spouses are Employed in Same Business; IRC: 402(h)(2), 415(c), and 404(h); 414(q)(6). SEP Contributions; Timing of Contribution Deduction; IRC: 404(h)(1)(B), 1366(a) and 1363(b). SEP/IRA; Deductibility of Contributions; IRC: 162. Signing Bonus; Immediate Deductibility vs. Capitalization; IRC: 162, 263. SIMPLE Plans; SIMPLE Plans, Compensation Definition and Limits; IRC 408(p). Treaty Protection for Compensation; Amounts Paid to Mexican National; IRC 3121(d)(1), 3306(i), and 3401(c). Withholding; Foreign Service Providers; IRC: 7701(b)(3), 1441, 1442. Withholding; Foreign Workers; IRC: 3402(a)(1), 3401(a), 3121(b), 3306(c).