Understanding the interrelationship of transfer pricing and tariffs is key to mitigating the effect of those levies on ...

New final regulations pose significant implications for possible income inclusions by U.S. corporations with foreign ...

Under Regs. Sec. 1.987-15, the 2024 final regulations generally apply to tax years beginning after Dec. 31, 2024, as ...

Properly established and maintained, an incomplete gift nongrantor trust may play a valuable role in some clients’ estate ...

Sec. 541 imposes a 20% tax on the undistributed personal holding company income of a personal holding company. Initially ...

The Tax Adviser—the magazine of planning, trends, and techniques—reports and explains federal tax issues to tax practitioners.

Determining when energy property is eligible for a tax credit or deduction hinges on when it is first placed in service, which can be controversial.

Planning with revocable trusts has become increasingly popular in recent years. In many instances, the motives for using a revocable trust are nontax and include avoiding probate, asset protection ...

The IRS may apply the step-transaction doctrine, a rule of substance over form, in a variety of taxpayer circumstances to deny tax benefits derived from a series of transactions that should more ...

Taxpayers generally must capitalize amounts paid to improve a unit of property. A unit of property is improved if the cost is made for (1) a betterment to the unit of property; (2) a restoration of ...

An S corporation, unlike a C corporation, generally escapes income tax at the corporate level; instead, its items of income, deduction, credit, etc., flow through to its shareholders, who calculate ...

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. It ...