The Tax Adviser12h
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 Adviser8h
FinCEN extends BOI reporting deadline, halts enforcement
The Financial Crimes Enforcement Network said late Thursday that it will extend the current reporting deadline beyond March 21 and will develop new regulations to reduce “regulatory burden.” ...
The Tax Adviser12h
New IRS form for partners receiving property distributions
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 Tax Adviser12h
Tax Court again holds Sec. 6038(b)(1) penalties not assessable
Reconsidering its earlier holding in the case, the court again held the IRS lacks statutory authority to assess the penalties for failing to file information returns disclosing ownership in foreign ...
The Tax Adviser12h
Transfer pricing: The C-suite needs to be informed
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 Adviser12h
Mandatory basis adjustments for certain LLC transfers
The partnership-level adjustment may be required for a substantial built-in loss, except for electing investment partnerships and securitization partnerships.
The Tax Adviser12h
States continue to tweak NOL provisions
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 changes the ...
The Tax Adviser12h
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 Adviser12h
Using role playing in a tax classroom
Students role playing tax preparers and clients can thereby apply their tax knowledge interactively, inculcating critical real-world interpersonal skills.
The Tax Adviser12h
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 Adviser12h
Taxpayer denied theft loss deduction for investment loss
The Tax Court focused on the taxpayer’s role as president and managing director of the company in which he invested, along with his failure to prove a theft occurred.
The Tax Adviser6mon
C Corporation Income Taxation
The regulations terminate the continued application of the Sec. 367(d) annual inclusion in certain cases when intangible property is repatriated to the United States after previously being transferred ...