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L TE F O T E ETR R M H

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Dear Clients and Friends of SingerLewak: Year-end tax planning is especially challenging this year because of uncertainty over whether Congress will enact sweeping tax reform that could have a major impact in 2012 and beyond. And even if there's no major tax legislation in the immediate future, ... [READ MORE]

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 Adviser publication. In the November 2011 edition, eleven articles demonstrating our range of technical knowledge at SingerLewak were published in the Tax Advisers Tax Clinic section edited by our tax partner, Mark Cook. These articles were great resources for businesses, individuals and estates, and you can review them here:

THE TAX ADVISER Updated Guidance on the Determination of Basis of Stock in Transferred Basic Transactions By Rina Pineda, CPA, MST - Woodland Hills Rev. Proc. 2011-35 was issued in response to the increasing difficulty of determining the transferred basis in stock associated with type B reorganizations as defined in Sec. 368 (a)(1)(B), particularly when the stock is publicly traded. [READ MORE] International Students and the American Opportunity Tax Credit By Seth M. Colwell, CPA, M. Tax Editor: Mark Cook, CPA, MBA - Irvine On February 17, 2009, President Barack Obama signed the American Recovery and Reinvestment Act of 2009, P.L. 111-5, which created the American opportunity tax credit (AOTC). [READ MORE] Revisiting the New Markets Tax Credit By Sarah Lovinger - Irvine The new markets tax credit (NMTC) was enacted under the Community Renewal Tax Relief Act of 2000, P.L. 106-554, and was incorporated into the Internal Revenue Code as Sec. 45D. [READ MORE] The Codified Economic Substance Doctrine and Related Penalties By David Yu - Irvine The IRS issued a directive on July 15, 2011, from its Large Business and International (LB&I) Division (LB&I-4-0711-015) to help examiners and their managers determine the appropriateness of seeking the approval of the director of field operations (DFO) when raising the economic substance doctrine. [READ MORE] Employers Immune from Suite for Complying with IRS Levy By Michael P. Mansour - Los Angeles

When a taxpayer fails to satisfy his or her tax liabilities, the IRS has an array of administrative tools for obtaining taxpayerscompliance. [READ MORE] Offers in Compromise and the Consideration of Disspated Assets By Andres Molgora, CPA - Los Angeles Since 2008, with the decline in the U.S. economy, the IRS has seen an increase in requests for offers in compromise from financially strapped taxpayers. [READ MORE] IRS Revamps Lien Procedures to Help Struggling Taxpayers By Anne Chang, CPA - Irvine Since 2008, many taxpayers have been facing unusual financial difficulties due to the economic downturn. As a corollary, some individuals and families have been unable to keep current on their tax obligations. [READ MORE] California Changes Combined Reporting for Assignment of Combined Group Sales By Jonathan E. Kraft - Los Angeles On May 26, 2011, Californias Franchise Tax Board (FTB) held an interested parties meeting to discuss possible amendments to the regulations pertaining to the assignment of sales of tangible personal property by members of a combined reporting group. [READ MORE] California's Click-Through Nexus Law By Christian J. Burgos, J.D., LL.M. - Los Angeles On June 28, 2011, California Governor Jerry Brown signed a click-through nexuslaw requiring out-of-state online retailers to collect sales tax on all taxable sales of tangible personal property made through internet-based referrals (CA AB 28, Laws 2011). [READ MORE] Software and California Sales and Use Tax By Christian J. Burgos, J.D., LL.M. - Los Angeles The taxability of software for sales and use tax purposes has been a point of persistent debate among states for several years. Many states, including California, have applied sales tax to software based on the form in which it is sold and delivered to consumers. [READ MORE] Deferral of Income from Sale of Gift Cards By Mark Brown - Irvine In recent years, retailers have experienced a significant increase in the sale of gift cards, which have become a large percentage of total sales. [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

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