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

Current developments in S corporations This annual update covers recent developments relating to S corporations, including IRS relief for common inadvertent S election lapses; the transfer of ...

Countries are expanding e-invoicing and digital reporting obligations to nonresidents to increase value-added-tax compliance.

Disregarded-payment-loss rules: How multinationals should prepare New final regulations pose significant implications for possible income inclusions by U.S. corporations with foreign disregarded ...

Recent final regulations offer guidance as to what Treasury and the IRS may consider an eligible method for partnerships and Sec. 987 QBUs held by partnerships to determine Sec. 987 gain or loss.

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

Editor: Mo Bell-Jacobs, J.D. Federal income tax credits have been used to incentivize investment in clean – energy projects for decades. The Sec. 48 energy credit is a component of the Sec. 46 ...

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.

CEOs need to understand the arm’s-length rules for transactions between commonly controlled entities because of the enormous amounts at stake in tax disputes, financial reporting risk from uncertain ...

While the benefit of equity compensation packages is easy to understand, the same cannot be said of the tax implications, and this article provides a broad overview of them.