A common cross-border reorganization can doom eligibility for the valuable gain exclusion without thoughtful planning.

Current developments in S corporations This annual update covers recent developments relating to S corporations, including IRS relief for common inadvertent S election lapses; the transfer of ...

Specific requirements apply to the adequate disclosure of transactions on a gift tax return.

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 ...

Sec. 83 governs the tax treatment of digital assets that employees receive in connection with their performance of services.

Taxation of undocumented immigrants Certain tax rules and considerations specifically affect undocumented immigrants in the United States and their common circumstances, such as being ineligible for ...

The Fifth Circuit’s decision in Grigsby, 86 F.4th 602 (5th Cir. 2023), emphasizes the need for taxpayers to clearly define business components when preparing and documenting their Sec. 41 credit.

Businesses that own, lease, or charter aircraft should prepare for increased IRS scrutiny by closely reviewing their compliance with applicable tax provisions.

CEOs need to understand the arm’s-length rules for transactions between commonly controlled entities because of the enormous amounts at stake in tax disputes, financial reporting risk from uncertain ...

While the benefit of equity compensation packages is easy to understand, the same cannot be said of the tax implications, and this article provides a broad overview of them.

Be aware of the self-rental rules when a taxpayer owns an operating business and leases property to it through a separate entity that the taxpayer also owns. Self-rentals can create both tax planning ...

Editor: Mary Van Leuven, J.D., LL.M. Taxpayers facing transfer-pricing adjustments should be aware of rules requiring secondary adjustments. The purpose of these adjustments is to resolve ...