The Tax Adviser16 天
On DRD, the IRS seeks to have its cake and eat it too
The plain language of Sec. 245A disallowed a dividends-received deduction for a controlled foreign corporation, the IRS ...
The Tax Adviser16 天
The CFC/PFIC overlap rule after aggregate treatment
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 Tax Adviser9 天
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 Adviser16 天
Payments for law violation are not deductible restitution
A recent Chief Counsel Advice memo determined that the deductions were disallowed as fines or penalties under Sec. 162(f).
The Tax Adviser16 天
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 Adviser3 年
Taxation of Estates & Trusts
Today’s low interest rates make charitable lead trusts a more powerful option for tax-efficient estate planning. These trusts can be advantageous to wealthier clients, but their future use in estate ...
The Tax Adviser16 天
New IRS form for partners receiving property distributions
Editor: Greg A. Fairbanks, J.D., LL.M. The IRS released a draft form in summer 2024, with subsequent revisions and draft instructions, that partners will use, starting with tax years beginning in 2024 ...
The Tax Adviser16 天
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 Adviser2 个月
C Corporation Income Taxation
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 Tax Adviser7 个月
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 Adviser9 年
About The Tax Adviser
The Tax Adviser is a monthly publication of the American Institute of CPAs, providing tax practitioners with timely, in-depth, practical, and comprehensive information on federal and state tax ...