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