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

Problems with S elections frequently cause them to be invalid when made or to terminate. This article discusses four of the ...

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

Examining a personal financial planning scenario can help students develop the application and analysis skills necessary to ...

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

Another item for U.S. inpatriates to consider is potentially having to pay taxes on foreign currency gain when they pay off their non – U .S. mortgage. If an individual pays off a non – U .S. mortgage ...

At $3,000 and never adjusted for inflation during nearly a century, the Sec. 861(a)(3) de minimis exception seldom applies.

A handwritten signature was not required on a petition filed with the Tax Court that was created on the court’s online petition generator.

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 ...

Recent final regulations offer guidance as to what Treasury and the IRS may consider an eligible method for partnerships and Sec. 987 QBUs held by partnerships to determine Sec. 987 gain or loss.

The state’s CAT regulations specifically provide that if health care services are performed in Ohio, 100% of the gross receipts are sourced there. If a health care service is provided partly in and ...

Further, these partnerships often invest in foreign entities. Many partners, especially limited partners, have no ability to direct the partnership’s operations and investment choices. Since foreign ...