Specific tax issues

I have provided tax advice to publicly traded companies, closely held companies and partnerships, and CPA firms in the following areas:

Accrual of income
Advance payments (Rev. Proc. 2004-34 and Treas. Reg. § 1.451-5)
Accrual of expenses
Inventory issues -- subnormal goods, lower of cost or market
Analysis of LIFO issues -- bargain purchases, conformity, pooling, whether to use IPIC
Methods of accounting
Changes in accounting methods
Changes in annual accounting periods
Bonus depreciation
IRC § 263A
Capitalization issues
R&D costs and R&D credit
Bad debt deductions

FBAR reporting

Passive activity losses
IRC § 754 elections
Elections under IRC § 761 to be excluded from subchapter K
Like kind exchanges
Purchase price adjustments
Installment sales

Treaty issues with Japan, Korea and other countries

Corporate reorganizations and spin-offs
Corporate liquidations
IRC § 338(h)(10) elections
S elections
Consolidated return issues
Tax planning for NOLs
Tax treatment of settlement payments

Preparation of responses to IRS examining agents
Protests to IRS Appeals
Litigation in U.S. Tax Court


The information you obtain at this site is not, nor is it intended to be, legal advice. You should consult an attorney for individual advice regarding your own situation.