The Tax Adviser

Digital asset transactions: Broker reporting, amount realized, and basis

In December 2022, Treasury and the IRS stated that they intended to implement the Infrastructure Act amendments to the Code by issuing new regulations and providing forms and instructions for broker ...
The Tax Adviser

Planning with charitable remainder trusts

First, ordinary income and such undistributed income of the trust for prior years; Second, capital gain (including unrecaptured Sec. 1250 gain and gain on collectibles taxed at 28%) and such ...
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

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

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

How S elections go wrong and how to fix them

To be an S corporation is to live dangerously. After all, in order to be taxed as an S corporation, the corporation 1 must file a complete and timely election with the IRS and meet and maintain strict ...
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 ...
The Tax Adviser

Sec. 280G and the evolving executive compensation landscape

Editors: Alexander J. Brosseau, CPA, and Greg A. Fairbanks, J.D., LL.M. Sec. 280G was enacted to address the potential for “golden parachutes” paid in connection with a corporate transaction that ...
The Tax Adviser

Transfer pricing: The C-suite needs to be informed

For the most part, the CEOs of large multinational corporations (MNCs) do not need to know much about tax issues. CEOs are already busy, charged with developing a vision and strategy for growth, ...
The Tax Adviser

Stock-based compensation: Tax forms and implications

Many companies provide stock (i.e., equity) compensation packages to employees. From an employer’s perspective, there are many benefits. First, it helps the company avoid paying higher cash salaries.