The Tax Adviser

AI’s role in complex tax decisions

John has served as an integral part of Drake Software since 1995 in roles including CFO and CRO. A CPA since 1989, he holds degrees from Oral Roberts University and the University of Tennessee, with ...
The Tax Adviser

Preserving the limitation statute for ERC claims

Under normal IRS procedures, filing a written protest contesting a disallowance gets a case in front of an IRS Appeals officer for consideration. After all, the IRS has disallowed the claim at this ...
The Tax Adviser

Global expansion of e-invoicing and digital reporting obligations for nonresidents

Editor: Mary Van Leuven, J.D., LL.M. Mary Van Leuven, J.D., LL.M., is a director, Washington National Tax, at KPMG LLP in Washington, D.C. For additional information ...
The Tax Adviser

Microcaptive insurance arrangements subject to new rules

This article examines the final regulations governing microcaptive insurance arrangements and their effect on taxpayers and their advisers. For background, this article also provides an overview of ...
The Tax Adviser

CHIPS Act final regs. offer many taxpayer-friendly provisions

The final regulations 1 issued by Treasury and the IRS to implement the advanced manufacturing investment credit (AMIC) include many taxpayer–friendly provisions. Found in Sec. 48D, the AMIC benefits ...
The Tax Adviser

The proposed PTEP rules: Tax basis considerations under Sec. 961

The IRS and Treasury on Nov. 29, 2024, released proposed regulations (REG-105479-18) addressing previously taxed earnings and profits (PTEP) of foreign corporations. The proposed regulations provide ...
The Tax Adviser

Disregarded-payment-loss rules: How multinationals should prepare

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 Adviser

Adequate disclosure on gift tax returns: A requirement for more than gifts

Taxpayers may be subject to the risk that an IRS examination could increase (or create) a gift tax or estate tax liability many years after a gift is made. Practitioners can help clients limit this ...
The Tax Adviser

Elections under the new Sec. 987 final regs.

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, ...
The Tax Adviser

Taxation of undocumented immigrants

Undocumented immigrants venture to the United States from all parts of the world and endure enormous challenges in their new life, ranging from cultural ones to those that are language–oriented in ...
The Tax Adviser

Planning for the AMT

Individuals are subject to two income tax systems: the regular income tax and the alternative minimum tax (AMT). Taxpayers must compute their tax under each system and pay the greater of the two ...
The Tax Adviser

IRS increases scrutiny of business aircraft use

In February 2024, the IRS announced it would be significantly increasing scrutiny of the use of noncommercial business aircraft by corporations, partnerships, and high–income taxpayers (e.g., business ...