A common cross-border reorganization can doom eligibility for the valuable gain exclusion without thoughtful planning.

There is much discussion around changes in the accounting profession due to generational shifts and the impact that technology has on the profession. As we discussed in a previous column (Walker, “ ...

Specific requirements apply to the adequate disclosure of transactions on a gift tax return.

Editor: Jeffrey N. Bilsky, CPA Non – U.S. directors who attend board meetings in the United States may discover that their temporary presence can create unexpected U.S. tax implications — both for ...

Sec. 83 governs the tax treatment of digital assets that employees receive in connection with their performance of services.

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.

Businesses that own, lease, or charter aircraft should prepare for increased IRS scrutiny by closely reviewing their compliance with applicable tax provisions.

Be aware of the self-rental rules when a taxpayer owns an operating business and leases property to it through a separate entity that the taxpayer also owns. Self-rentals can create both tax planning ...

Editor: Mary Van Leuven, J.D., LL.M. Taxpayers facing transfer-pricing adjustments should be aware of rules requiring secondary adjustments. The purpose of these adjustments is to resolve ...

Only certain types of trusts are permitted to hold an interest in an S corporation. Two of these are an electing small business trust, or ESBT, and a qualified Subchapter S trust, or QSST. An ESBT is ...

This article discusses the history of the grantor trust rules, how they are exploited to avoid taxes, and ways the rules might be reformed to prevent them from being used for tax avoidance.

New regulations providing guidance on the application of the Sec. 163(j) interest expense limitation may change how some companies calculate their naked credit.