This annual update on trust, estate, and gift taxation covers recent IRS guidance and administrative issuances, relevant ...
A taxpayer’s extension of variable prepaid forward contracts resulted in a constructive sale and a termination of obligations ...
Business advisers can help guide clients through the tax and accounting considerations of a corporate sale or purchase.
Stock value premium over fair market value as either compensation or capital gain can be a facts-and-circumstances ...
Determining whether an ownership change under Sec. 382 has occurred can hinge on understanding the shareholder aggregation ...
In their reasonable reliance on software under Statement on Standards for Tax Services 1.4, AICPA members should evaluate its ...
This annual update on trust, estate, and gift taxation covers recent IRS guidance and administrative issuances, relevant ...
LLCs changing from partnership tax treatment to corporation or vice-versa may encounter issues including gain recognition.
The Tax Court found a regulation invalid to the extent it holds the period open for the IRS to issue a final partnership adjustment longer than the statutory 270 days after a partnership has submitted ...
The IRS’s increased documentation requirements for Sec. 41 claims require taxpayers to specifically identify applicable business components and their costs and why their development is qualified ...
On remand from the Eighth Circuit and after the Supreme Court held in the case that the Sec. 6330(d)(1) period for filing a Tax Court petition for a review of a Collection Due Process determination is ...
After decades of limiting private letter ruling issues, the IRS has steadily widened its program, providing taxpayers greater certainty.
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