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

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

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 ...

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 ...

Tax practitioners should be familiar with the special rules that apply and issues that can arise when an accounting method change is made while a taxpayer is under IRS examination.

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.

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

In the rapidly evolving health care industry, organizational structures often include management services organizations (MSOs) to set apart clinical and nonclinical activities. The purpose of an MSO ...

The court refused to dismiss a taxpayer’s claim under Sec. 7431 against a company that employed an individual who made an unauthorized disclosure of the taxpayer’s tax return and information.

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 ...

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

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