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 court refused to dismiss a taxpayer’s claim under Sec. 7431 against a company that employed an individual who made an unauthorized disclosure of the taxpayer’s tax return and information.

Taxpayers may be subject to the risk that an IRS examination could increase (or create) a gift tax or estate tax liability many years after a gift is made. Practitioners can help clients limit this ...

Further, these partnerships often invest in foreign entities. Many partners, especially limited partners, have no ability to direct the partnership’s operations and investment choices. Since foreign ...

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

In the rapidly evolving health care industry, organizational structures often include management services organizations (MSOs) to set apart clinical and nonclinical activities. The purpose of an MSO ...

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