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.

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 ...

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.

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 ...

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

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 ...

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 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 ...

To get through the rigors of tax season, CPAs depend on their tax preparation software. Here's how they rate the leading professional products.