Sec. 1361 sets forth the basic qualifications for S corporation status. Among the most important are the limitation on types of shareholders and restrictions to a single class of stock. Tax Court ...
Just as for other businesses, tax considerations come to the fore when CPA practices combine. This article delves into some of the possible entity deal structures for CPA firm mergers and acquisitions ...
The IRS and Treasury on Nov. 29, 2024, released proposed regulations (REG-105479-18) addressing previously taxed earnings and profits (PTEP) of foreign corporations. The proposed regulations provide ...
For taxpayers that have a qualified business unit (QBU) with a functional currency other than the dollar, Sec. 987 provides rules on how to adjust for changes in exchange rates. On Dec. 10, 2024, ...
What do you do when the proverbial “tax man” is coming to collect on tens of billions of deferred gains? As part of the 2017 Tax Cuts and Jobs Act, 1 Congress established the qualified opportunity ...
Amid new limitations, strategies remain for optimizing tax-efficient support for colleges and universities.
Congress incentivized domestic manufacturing of semiconductors and semiconductor manufacturing equipment as part of the Creating Helpful Incentives to Produce Semiconductors (CHIPS) Act of 2022. To ...
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2024. Certain tax rules and ...
Adjustments under the disregarded-payment and foreign tax credit rules are often overlooked. This practical framework ...
Hedge funds may face tax issues of entity structuring, carried interest, management fee waivers, and trading-related rules. This article highlights planning strategies and compliance considerations as ...
The Fifth Circuit, overruling the Tax Court, held that for purposes of the Sec. 1402(a)(13) exclusion from self-employment tax, “limited partner” means a partner in a limited partnership that has ...
The Tax Court advised a taxpayer that filing a second petition would not allow another IRS Collection Due Process review.
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