The Tax Adviser10d
AICPA applauds Treasury's suspension of BOI enforcement
The AICPA said Treasury is "headed in the right direction" by suspending enforcement of beneficial ownership information (BOI) reporting requirements and urged it to extend reporting deadlines to at ...
The Tax Adviser17d
Transfer pricing: The C-suite needs to be informed
For the most part, the CEOs of large multinational corporations (MNCs) do not need to know much about tax issues. CEOs are already busy, charged with developing a vision and strategy for growth, ...
The Tax Adviser17d
Payments for law violation are not deductible restitution
Editor: Greg A. Fairbanks, J.D., LL.M. In Chief Counsel Advice memorandum (CCA) 202439015, the IRS Chief Counsel's Office determined that deductions claimed by a taxpayer for payments made to a ...
The Tax Adviser17d
States continue to tweak NOL provisions
Editor: Greg A. Fairbanks, J.D., LL.M. In response to federal changes to net operating losses (NOLs) and fluctuating fiscal conditions, several states have recently enacted noteworthy legislation that ...
The Tax Adviser17d
The CFC/PFIC overlap rule after aggregate treatment
Editor: Greg A. Fairbanks, J.D., LL.M. Historically, domestic partnerships and S corporations that owned 10% or more of a controlled foreign corporation (CFC) could rely on the so-called CFC/PFIC ...
The Tax Adviser17d
Mandatory basis adjustments for certain LLC transfers
Regardless of whether a limited liability company (LLC) has a Sec. 754 election in effect, a partnership-level tax basis adjustment is required when an LLC interest is transferred (including a ...
The Tax Adviser17d
Tax Court again holds Sec. 6038(b)(1) penalties not assessable
Between November 2001 and September 2005, Raju Mukhi created three foreign entities, including Sukhmani Partners II Ltd., a foreign corporation for U.S. tax purposes. From 2002 through 2013, Mukhi did ...
The Tax Adviser17d
On DRD, the IRS seeks to have its cake and eat it too
Editor: Greg A. Fairbanks, J.D., LL.M. The IRS Office of Chief Counsel released Chief Counsel Advice memorandum (CCA) 202436010 on Sept. 6, 2024, concluding that a controlled foreign corporation (CFC) ...
The Tax Adviser17d
Taxpayer denied theft loss deduction for investment loss
The Tax Court held that a taxpayer was not entitled to a Sec. 165 casualty or theft loss deduction for his lost investment in a company of which he was president for six months and later was its ...
The Tax Adviser7mon
Taxation of Estates & Trusts
The final regulations implement Sec. 2801, added to the Code in 2008, and follow up on proposed regulations issued 10 years ago. Changes to the qualified domestic trust regulations under Sec. 2056A ...
The Tax Adviser5mon
C Corporation Income Taxation
This article outlines a five-step process for calculating a corporate partner’s distributive share related to the application of the corporate alternative minimum tax imposed on an applicable ...