New final regulations pose significant implications for possible income inclusions by U.S. corporations with foreign ...

Under Regs. Sec. 1.987-15, the 2024 final regulations generally apply to tax years beginning after Dec. 31, 2024, as ...

Examining a personal financial planning scenario can help students develop the application and analysis skills necessary to ...

The Tax Adviser—the magazine of planning, trends, and techniques—reports and explains federal tax issues to tax practitioners.

Understanding the interrelationship of transfer pricing and tariffs is key to mitigating the effect of those levies on ...

Properly established and maintained, an incomplete gift nongrantor trust may play a valuable role in some clients’ estate ...

The Tax Adviser—the magazine of planning, trends, and techniques—reports and explains federal tax issues to tax practitioners.

Sec. 541 imposes a 20% tax on the undistributed personal holding company income of a personal holding company. Initially ...

Further, these partnerships often invest in foreign entities. Many partners, especially limited partners, have no ability to direct the partnership’s operations and investment choices. Since foreign ...

Tax practitioners should be familiar with the special rules that apply and issues that can arise when an accounting method change is made while a taxpayer is under IRS examination.

Determining when energy property is eligible for a tax credit or deduction hinges on when it is first placed in service, which can be controversial.

Taxpayers may be subject to the risk that an IRS examination could increase (or create) a gift tax or estate tax liability many years after a gift is made. Practitioners can help clients limit this ...