The plain language of Sec. 245A disallowed a dividends-received deduction for a controlled foreign corporation, the IRS ...

Investors holding less than 10% of a controlled foreign corporation (CFC) are generally no longer shielded from double taxation under both the passive foreign investment company and CFC rules.

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 ...

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, ...

Form 7217, Partner’s Report of Property Distributed by a Partnership, debuted for 2024, intended to apprise the IRS of factors in a partner’s basis computation.

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 ...

A recent Chief Counsel Advice memo determined that the deductions were disallowed as fines or penalties under Sec. 162(f).

CEOs need to understand the arm’s-length rules for transactions between commonly controlled entities because of the enormous amounts at stake in tax disputes, financial reporting risk from uncertain ...

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 ...

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