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The Tax Adviser14d
Corporate Finance & Treasury Management
The Tax Adviser—the magazine of planning, trends, and techniques—reports and explains federal tax issues to tax practitioners.
The Tax Adviser23d
Disregarded-payment-loss rules: How multinationals should prepare - The Tax Adviser
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 Adviser26d
Adequate disclosure on gift tax returns: A requirement for more than gifts - The Tax Adviser
Editor: Jeffrey N. Bilsky, CPA. Professionals are currently advising clients amid the so – called “great wealth transfer”; new IRS campaigns focused on high – income / high – wealth taxpayers; and the ...
The Tax Adviser26d
Why non-US directors can rarely exempt US-source compensation from US income tax - The Tax Adviser
Editor: Jeffrey N. Bilsky, CPA. Non – U.S. directors who attend board meetings in the United States may discover that their temporary presence can create unexpected U.S. tax implications — both for ...
The Tax Adviser26d
How S elections go wrong and how to fix them - The Tax Adviser
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 Adviser26d
Sec. 541: A trap for the unwary investment partnership
Editor: Jeffrey N. Bilsky, CPA. Sec. 541 imposes a 20% tax on the undistributed personal holding company income of a personal holding company. Initially enacted in 1934, the tax was intended to ...
The Tax Adviser26d
Tax accounting method changes: Procedures and potential issues during an IRS exam - The Tax Adviser
Editor: Jeffrey N. Bilsky, CPA. Since the passage of the Inflation Reduction Act of 2022, P.L. 117 – 169, the IRS expanded its enforcement activity, including increased exams of complex business ...
The Tax Adviser29d
Elections under the new Sec. 987 final regs. - The Tax Adviser
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, ...
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Placing in service the benefits of the Inflation Reduction Act - The Tax Adviser
As the world heads toward a greener future, companies that invest in renewable energy projects within the United States have more opportunities for tax credits and other financial incentives than ever ...
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Treatment of digital assets transferred to employees - The Tax Adviser
Editor: Mo Bell-Jacobs, J.D. The IRS has issued extensive guidance on treating payments to employees and other service providers as compensation, including how to report such compensation and the ...
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Combining debtor and creditor positions: COD income considerations - The Tax Adviser
Editor: Mo Bell-Jacobs, J.D. Like all taxpayers, companies must realize any income that results from the cancellation of debt (COD). A COD event can occur in various situations, including an actual ...
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Deemed liquidation on electing QSub status - The Tax Adviser
A qualified Subchapter S subsidiary (QSub) is a subsidiary corporation 100% owned by an S corporation that has made a valid QSub election for that subsidiary. In addition to being 100% owned by an S ...