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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
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
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 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
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
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 ...
The Tax Adviser29d
Integrating personal financial planning into individual income tax courses - The Tax Adviser
Contributors. Brianne C. Smith, CPA/ABV/PFS, Ph.D., is an assistant professor of accounting in the School of Accountancy at Auburn University at Montgomery, Ala., and managing member of Brianne CPA, ...
The Tax Adviser29d
Sec. 541: A trap for the unwary investment partnership
Editor: Jeffrey N. Bilsky, CPA. Sec. 541 imposes a 20% tax on the undistributed personal holding company income of a personal holding company. Initially enacted in 1934, the tax was intended to ...
The Tax Adviser29d
Sec. 987 final regulations: A practical approach for partnerships - The Tax Adviser
Editor: Jeffrey N. Bilsky, CPA. On Dec. 10, 2024, Treasury and the IRS issued final and proposed regulations under Sec. 987 (T.D. 10016 and REG – 117213 – 24).The Sec. 987 regulations provide guidance ...
The Tax Adviser29d
Tax planning for health care management services organizations - The Tax Adviser
In the rapidly evolving health care industry, organizational structures often include management services organizations (MSOs) to set apart clinical and nonclinical activities. The purpose of an MSO ...
The Tax Adviser29d
Deferred revenue: Transactional triggering events - The Tax Adviser
Editor: Jeffrey N. Bilsky, CPA. Operating businesses in various industries often receive advance payments for goods or services that will be provided in the future, and the presence of deferred or ...
The Tax Adviser19d
Using transfer pricing to blunt the effects of tariffs
In our global economy, even a tariff of less than 10% can have a significant impact on the supply chains that cross national borders. Blanket tariffs of 10% and “reciprocal” tariffs of well over 25% ...