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sec

Abbreviation for second.
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Because Sec. 199 results in a deduction for qualifying taxpayers, questions began to arise shortly after the section's enactment that relate to the interplay of the deduction with other Code provisions.
Interplay between the Sec. 199 manufacturing deduction and the Sec. 965 repatriation provision
Under Sec. 419(c)(3), a benefit's qualified direct cost in any year is that year's cost of providing the benefit, plus related administrative costs, based on the cash method of accounting.
Is a single-employer welfare benefit plan appropriate for a small business?
* The IRS is studying the current Sec. 751(b) regulations and considering alternative approaches to achieve Sec.
Current developments: this article reviews and analyzes recent rulings and decisions involving partnerships. The discussion covers developments in partnership formation, foreign-source income, debt and income allocations, partnership continuation and basis adjustments
Pursuant to Sec. 645, if both the executor (if any) of an estate and the trustee of a qualified revocable trust so elect, the "electing" trust--a qualified revocable trust (QRT) that makes the Sec.
Trust treatment: final regs issued on election to treat revocable trusts as part of estate
The TIPRA made significant changes to the Sec. 355 spinoff rules.
Significant recent developments
We suggest two ways to help IRC Secs. 1202 and 1045-related issues result in positive client interactions.
Paving the Way
* The Service issued additional guidance on the interpretation of plans under Sec. 355(e) and elections under new Sec.
Significant recent developments
In the past year, Treasury issued final regulations (4) on a partnership's obligation to withhold tax on effectively connected taxable income allocable to a foreign partner under Sec. 1446.
Current developments
The Tax Court held that TLC was subject to the Sec. 274(n) limit on per-diem meal expense allowances it paid to the drivers, because it was the driver's common-law employer (see Transport Labor Contract /Leasing, Inc., 123 TC 154 (2004)).
Lessor of truck driver employees avoids 50% limit on per diems
Sec 199 provides a deduction equal to 3% (increasing to 6% for 2007, 2008 and 2009 and then to 9% for 2010 and there after) of the lesser of qualified production activities income (QPAI) or taxable income.
Allocation and apportionment of expenses for Sec. 199 purposes: for many taxpayers, calculation of the Sec. 199 deduction will require an enormous amount of work. This article focuses on one aspect of the deduction, the allocation and apportionment of expenses under the Sec. 861 regulations and the proposed Sec. 199 regulations
This two-part article offers guidance on Sec. 66 relief for married clients who are separated and reside in community property states.
Treatment of community income for spouses living apart: Sec. 66 may relieve a separated spouse of the duty to report a portion of the other spouse's community property income. Part I of this two-part article discusses the requirements for relief under sec. 66(a) and denial of community property benefits under sec. 66(b)
In most transactions, the amount of ordinary income recognized under Sec. 1245 for an item of property equals the lesser of the gain on the particular item of Sec.
Intangibles - amortization recapture and allocation of sales price

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