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Understanding the interrelationship of transfer pricing and tariffs is key to mitigating the effect of those levies on ...
The Tax Adviser—the magazine of planning, trends, and techniques—reports and explains federal tax issues to tax practitioners.
The 549-page text calls for making many provisions of the Tax Cuts and Jobs Act permanent. The committee says that the SALT cap amount is “the subject of continuing negotiations.” A letter from the ...
A notice issued by the IRS with interim guidance for the application of the corporate alternative minimum tax offers an optional simplified method for determining applicable corporation status under ...
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 ...
Planning with revocable trusts has become increasingly popular in recent years. In many instances, the motives for using a revocable trust are nontax and include avoiding probate, asset protection ...
Each year, tax professionals who deal with real estate must evaluate the most recent building expenditures and determine which items should be deducted as a repair expense or capitalized. Of all the ...
The IRS may apply the step-transaction doctrine, a rule of substance over form, in a variety of taxpayer circumstances to deny tax benefits derived from a series of transactions that should more ...
A qualified Subchapter S subsidiary (QSub) is a subsidiary corporation 100% owned by an S corporation that has made a valid QSub election for that subsidiary. In addition to being 100% owned by an S ...
The federal income taxation of gains (and losses) from the disposition of investments in collectible assets (collectibles) is relatively unfamiliar to many practitioners for several reasons. First, ...
A recent circuit court case, Grigsby, 1 emphasizes the need for taxpayers to clearly define business components when preparing and documenting their Sec. 41 research tax credit. The Fifth Circuit ...