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27 Tax Adviser [i] (1996)

handle is hein.journals/txadv27 and id is 1 raw text is: THETAX A MAGAZINE OF PLANNING, TRENDS & TECHNIQUES JANUARY 1996 23 Technoogy: Tips, Tricks and Traps of CD-ROM Tax Research (Part II) 28 Foreign Income & Taxpayers: Tax Court's Taisei Case Sheds Light on the Definition of Permanent Establishment 34 Real Estate: When and How to Avoid Sec. 1038 Relief When Reacquiring Real Property 38 The Tax Adviser Is Now Available on CompuServe 8 TAX CLINIC Bargain purchases of inventory • Depreciation of property under accelerator leases • Captive insur- ance arrangements • Partnership's distribution of stock received in reorg. and continuity-of-interest requirement • Target stock acquired in anticipation of merger and continuity-of-interest requirement • IRS positions on grantor trusts • Joint venture to construct and operate elder-care facility • Bonus payments to key employees required to sell ISO stock •Just-in-time implementation costs • Employer's reimbursement of employees' health insurance deductible • Hospital discounts to classes of patients • Payments to lawyer serving on client's board of directors • Rental income from wholly owned cash method corporation • Qualified stated interest on debt instruments • Substantial allocation of contributed property • Dual Sec. 401(k)/nonqualified deferred compensation arrangement • Employer's compensation for employee plan's losses • Rollover of plan benefits • Form 8275 disclo- sure • Most current data requirement for transfer pricing • Penalties for failure to file agency autho- rization 6 ....................................................News Notes 41 .................................Computers in Taxation 44 .....................................................Case Study A ..........................................Tax Trends Digitized from Best Copy Available

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