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 ...

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.

Determining when energy property is eligible for a tax credit or deduction hinges on when it is first placed in service, which can be controversial.

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

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 ...

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 ...