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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-
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-
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.


Taxing Decisions
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