This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance ...
Determining the appropriate tax treatment of an investment fund’s waived management fee involves a number of factors, the ...
High‑net‑worth families can preserve wealth across generations by pairing intentionally defective grantor trusts with ...
Proactive management of net unrealized built-in losses in ownership changes is increasingly important in today’s volatile ...
A variety of capitalization strategies can increase deductible interest expense now that depreciation, amortization, and ...
With enhanced Sec. 1202 gain exclusion, permanency of Sec. 199A, and other provisions, the calculus for entity choice has ...
Before adopting the newly reinstated expensing of research and experimental expenditures, taxpayers should first consider the ...
A foreign employer’s duty to comply with U.S. payroll tax rules for employees who work in the United States can give rise to ...
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance ...
The Tax Court held that taxpayers who refused to meet with IRS Appeals after being offered a conference had been given the opportunity to dispute Sec. 6707 penalties assessed against them by the IRS.
On Jan. 10, 2025, Treasury and the IRS released final regulations (T.D. 10022) addressing the classification of digital content and cloud transactions. Proposed regulations (REG–107420–24) were issued ...
The Fifth Circuit’s decision in Grigsby, 86 F.4th 602 (5th Cir. 2023), emphasizes the need for taxpayers to clearly define business components when preparing and documenting their Sec. 41 credit.
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