To avoid contending with the complex and time-consuming calculations of the uniform capitalization rules under Sec. 263A, taxpayers may want to consider electing the historic absorption ratio with ...

New final regulations pose significant implications for possible income inclusions by U.S. corporations with foreign ...

Properly established and maintained, an incomplete gift nongrantor trust may play a valuable role in some clients’ estate ...

Examining a personal financial planning scenario can help students develop the application and analysis skills necessary to ...

Under Regs. Sec. 1.987-15, the 2024 final regulations generally apply to tax years beginning after Dec. 31, 2024, as ...

Sec. 541 imposes a 20% tax on the undistributed personal holding company income of a personal holding company. Initially ...

The IRS may apply the step-transaction doctrine, a rule of substance over form, in a variety of taxpayer circumstances to deny tax benefits derived from a series of transactions that should more ...

Matthew Gotlin, CFA, MBA, Chief Investment Officer and Managing Director, Wealth Management, ChoreoMatt leads the firm’s ...

Recent final regulations offer guidance as to what Treasury and the IRS may consider an eligible method for partnerships and Sec. 987 QBUs held by partnerships to determine Sec. 987 gain or loss.

At $3,000 and never adjusted for inflation during nearly a century, the Sec. 861(a)(3) de minimis exception seldom applies.

The Fifth Circuit’s decision in Grigsby, 86 F.4th 602 (5th Cir. 2023), emphasizes the need for taxpayers to clearly define business components when preparing and documenting their Sec. 41 credit. It ...

Taxpayers generally must capitalize amounts paid to improve a unit of property. A unit of property is improved if the cost is made for (1) a betterment to the unit of property; (2) a restoration of ...