This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance ...
High‑net‑worth families can preserve wealth across generations by pairing intentionally defective grantor trusts with ...
Determining the appropriate tax treatment of an investment fund’s waived management fee involves a number of factors, the ...
A variety of capitalization strategies can increase deductible interest expense now that depreciation, amortization, and ...
A foreign employer’s duty to comply with U.S. payroll tax rules for employees who work in the United States can give rise to ...
Before adopting the newly reinstated expensing of research and experimental expenditures, taxpayers should first consider the ...
With enhanced Sec. 1202 gain exclusion, permanency of Sec. 199A, and other provisions, the calculus for entity choice has ...
Proactive management of net unrealized built-in losses in ownership changes is increasingly important in today’s volatile ...
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance ...
The table “1. Sample Rate Analysis” illustrates the interaction of jurisdictional income taxes assuming a domestic, U.S.-domiciled PBE that apportions 100% of its income to one state. The United ...
The Tax Court held that taxpayers who refused to meet with IRS Appeals after being offered a conference had been given the opportunity to dispute Sec. 6707 penalties assessed against them by the IRS.
On Jan. 10, 2025, Treasury and the IRS released final regulations (T.D. 10022) addressing the classification of digital content and cloud transactions. Proposed regulations (REG–107420–24) were issued ...
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