A IRS Publications 4557, 1345, and 5709 are foundational for safeguarding taxpayer data and great resources for you to start ...
Nonresident alien’s Sec. 751 gain on sale of partnership interest was sourced to United States.
Disguised sale occurs when a partner(s) engages in a transaction that, when viewed together with a partnership, involve property and are characterized as the sale or exchange of property. This ...
Partnerships’ administrative adjustment requests filed under the Bipartisan Budget Act rules can affect partners in disparate ways, including where adjustments flow through a tiered structure. The Tax ...
This item provides an overview of the division rules and touches on some key issues to consider when a transaction involves a partnership division.
Fiscal 2023 tax provisions also would increase IRS funding, encourage domestic business investments, and repeal many fossil fuel tax preferences. Taxpayers should strongly consider these letter ...
Gain on the disposition of controlled foreign corporation stock, in excess of the amount of gain required to be recognized as foreign income to offset a taxpayer’s overall foreign loss under Sec.
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Treasury and the IRS withdrew parts of proposed net value regulations that would require an exchange of net value for transactions intended to qualify under Secs. 351 and 368 and a distribution of net ...
The Tax Adviser is a monthly publication of the American Institute of CPAs, providing tax practitioners with timely, in-depth, practical, and comprehensive information on federal and state tax ...
In addition to the guidance on the plan, the letter recommends that Treasury and the IRS continue pursuing tax simplification. IRS commissioner Danny Werfel promised “marked improvement” for the ...