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The Tax Adviser—the magazine of planning, trends, and techniques—reports and explains federal tax issues to tax practitioners.
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 ...
New final regulations pose significant implications for possible income inclusions by U.S. corporations with foreign ...
Examining a personal financial planning scenario can help students develop the application and analysis skills necessary to ...
Properly established and maintained, an incomplete gift nongrantor trust may play a valuable role in some clients’ estate ...
Problems with S elections frequently cause them to be invalid when made or to terminate. This article discusses four of the ...
Sec. 541 imposes a 20% tax on the undistributed personal holding company income of a personal holding company. Initially ...
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 ...
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 ...
At $3,000 and never adjusted for inflation during nearly a century, the Sec. 861(a)(3) de minimis exception seldom applies.
Recent final regulations offer guidance as to what Treasury and the IRS may consider an eligible method for partnerships and Sec. 987 QBUs held by partnerships to determine Sec. 987 gain or loss.