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

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 ...

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

At $3,000 and never adjusted for inflation during nearly a century, the Sec. 861(a)(3) de minimis exception seldom applies.

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.

The court refused to dismiss a taxpayer’s claim under Sec. 7431 against a company that employed an individual who made an unauthorized disclosure of the taxpayer’s tax return and information.

Another item for U.S. inpatriates to consider is potentially having to pay taxes on foreign currency gain when they pay off their non – U .S. mortgage. If an individual pays off a non – U .S. mortgage ...

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 ...

The state’s CAT regulations specifically provide that if health care services are performed in Ohio, 100% of the gross receipts are sourced there. If a health care service is provided partly in and ...