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The Tax Adviser26d
Disregarded-payment-loss rules: How multinationals should prepare - The Tax Adviser
Treasury and the IRS on Jan. 10, 2025, released final regulations regarding dual-consolidated-loss (DCL) and disregarded-payment-loss (DPL) rules (T.D. 10026). These finalize proposed regulations ...
The Tax Adviser29d
How S elections go wrong and how to fix them - The Tax Adviser
To be an S corporation is to live dangerously. After all, in order to be taxed as an S corporation, the corporation 1 must file a complete and timely election with the IRS and meet and maintain strict ...
The Tax Adviser29d
Adequate disclosure on gift tax returns: A requirement for more than gifts - The Tax Adviser
Editor: Jeffrey N. Bilsky, CPA. Professionals are currently advising clients amid the so – called “great wealth transfer”; new IRS campaigns focused on high – income / high – wealth taxpayers; and the ...
The Tax Adviser29d
Tax accounting method changes: Procedures and potential issues during an IRS exam - The Tax Adviser
Editor: Jeffrey N. Bilsky, CPA. Since the passage of the Inflation Reduction Act of 2022, P.L. 117 – 169, the IRS expanded its enforcement activity, including increased exams of complex business ...
The Tax Adviser29d
ING trusts: How they work and their continued viability
In the context of trusts, CPAs may have heard someone mention WINGs, DINGs, or NINGs. This article aims to explain the advantages, requirements, and potential drawbacks of these trusts for estate ...
The Tax Adviser29d
Why non-US directors can rarely exempt US-source compensation from US income tax - The Tax Adviser
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 ...
The Tax Adviser29d
Partnership reporting of contributions to foreign entities - The Tax Adviser
Investors looking for greater diversification and opportunity often invest in partnerships to access private equity and other investments unavailable to the public. Further, these partnerships often ...
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Elections under the new Sec. 987 final regs. - The Tax Adviser
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, ...
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Taxation of undocumented immigrants - The Tax Adviser
Footnotes. 1 See, e.g., Davis, Guzman, and Sifre, “ Tax Payments by Undocumented Immigrants,” Institute on Taxation and Economic Policy (2024), estimating that “[u]ndocumented immigrants paid $96.7 ...
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Treatment of digital assets transferred to employees - The Tax Adviser
Editor: Mo Bell-Jacobs, J.D. The IRS has issued extensive guidance on treating payments to employees and other service providers as compensation, including how to report such compensation and the ...
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Legacy clean-energy credits evolve into tech-neutral credits - The Tax Adviser
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 ...
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Deemed liquidation on electing QSub status - The Tax Adviser
A qualified Subchapter S subsidiary (QSub) is a subsidiary corporation 100% owned by an S corporation that has made a valid QSub election for that subsidiary. In addition to being 100% owned by an S ...