The complexities of redeeming a partner’s interest in a partnership with payments over multiple years are increased when the redeemed partner receives a promissory note.
The rules for qualified small business stock become more complex when it is held through a pass-through entity or when the ...
Assumptions of receivables are usually straightforward, but debt transfers can in some instances be disallowed or even be considered abusive.
Collaboration agreements, especially in the life sciences, sometimes unexpectedly transcend state boundaries, with consequences for companies’ apportionment and sales factor revenue sourcing.
A recent IRS letter ruling and Tax Court case illustrate, respectively, successful and unsuccessful positions regarding foreign investments in the United States as effectively connected income.
Editor: Rochelle Hodes, J.D., LL.M. Employer-provided health coverage is one of the most widely relied-upon tax-favored benefits in the Internal Revenue ...
State authorities are increasingly scrutinizing companies’ escheats information regarding sourcing, dormancy tracking, and owners.
Tax-exempt hospitals should reassess how they document, report, and defend their benefit to the community to support continued exemption under Sec. 501(c)(3).
The Tax Adviser—the magazine of planning, trends, and techniques—reports and explains federal tax issues to tax practitioners.
The IRS issued final regulations increasing the cost of an estate tax closing letter to $76 from $56, adopting without change proposed regulations issued in June. The final regulations target ...
Drake Tax and Lacerte swapped places in that order compared to last year’s survey, with Drake Tax dropping 2 percentage points and Lacerte gaining nearly a point. Also notable was CCH Axcess Tax’s ...
This first part of a two–part series on taxpayer rights and Internal Revenue Manual (IRM) procedures addresses questions including whether an anticipated liability can be part of an installment ...