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25 Prac. Tax Law. 3 (2010-2011)

handle is hein.ali/practax0025 and id is 1 raw text is: The Practical Tax Lawyer volume 25 | number 1 I fall 2010 Health Care Reform For Small Employers Kelly A. Means, Richard A. Naegele William P. Prescott, and Mark P. Altieri 7 The new health care reform legislation exceeds 2,400 pag- es and is likely to change as more regulatory guidance is re- leased. This overview of health care reform will enable at- torneys working with small employers to prepare for the various health care reform provisions that will ultimately affect their clients in a number of ways, both positively and negatively. Although small employers are exempt from many of the health care reform mandates, many other mandates will significantly affect these employers. Sales To Intentionally Defective Grantor Trusts Mark S. Poker 15 This article provides an overview of the tax treatment, structure, and use of intentionally defective grantor trusts (IDGT). Particular focus is given to the benefits and risks associated with implementing IDGTs. IDGTs are com- pared to grantor retained annuity trusts (GRATs), and the economic impact of various IDGT designs is also ad- dressed. Administrative Audits: IRS Initiatives J. Bradford Anwyll and Collin F. Imhof 41 The IRS is undertaking many new initiatives in the ad- ministrative audit world, including the areas of voluntary disclosure and uncertain tax positions. This article reviews some of the more important of these initiatives, and how they will affect your clients. The Offer In Compromise Program May Offer Tax Relief To Financially Troubled Clients Robert F Reilly 49 As a result of the prolonged recession (including the associ- ated high unemployment rates and decreasing investment values), some business and individual taxpayers are not able to pay the full amount of their federal tax liabilities when they come due. There are several methods that such illiquid business and individual taxpayers may use to pay all or part of their federal tax liability. One of the common methods is for the business or individual taxpayer to make an offer in compromise (OIC) to pay a reduced amount of the total tax owed to the Internal Revenue Service (the Service). This article summarizes the procedures that both business and individual taxpayers can use to take ad- vantage of the OIC program. An Overview Of Tax Issues For Religious Congre- gations Ellen P. Aprill 55 Many tax lawyers are asked to serve on the governing bod- ies of their religious congregations. Yet religious congre- gations are subject to some unique rules that tax lawyers are unlikely to have encountered. This article discusses the issues that are most often asked (or should be asked), when giving pro bono advice to religious congregations. Included are requirements for setting compensation, lob- bying and political activities, substantiation of charitable contributions, charitable fundraising, payroll taxes and withholding for clergy, parsonage and housing allowances, and discretionary funds. 5 6 Taxing Decisions Publications and Playbacks To purchase the online version of this issue, go to www.ali-aba.org and click on Articles and Forms Online Back issues, individual articles, and forms are also available there.

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