Stock value premium over fair market value as either compensation or capital gain can be a facts-and-circumstances ...
A taxpayer’s extension of variable prepaid forward contracts resulted in a constructive sale and a termination of obligations that gave rise to taxable gain, the Tax Court held.
This annual update on trust, estate, and gift taxation covers recent IRS guidance and administrative issuances, relevant legislative proposals, and selected court decisions for the period ending June ...
In their reasonable reliance on software under Statement on Standards for Tax Services 1.4, AICPA members should evaluate its ...
The IRS’s increased documentation requirements for Sec. 41 claims require taxpayers to specifically identify applicable business components and their costs and why their development is qualified ...
LLCs changing from partnership tax treatment to corporation or vice-versa may encounter issues including gain recognition.
Determining whether an ownership change under Sec. 382 has occurred can hinge on understanding the shareholder aggregation and segregation rules.
Updating their fixed-asset records and exploring state exemptions can create often-missed tax savings for businesses.
After decades of limiting private letter ruling issues, the IRS has steadily widened its program, providing taxpayers greater certainty.
This annual update on trust, estate, and gift taxation covers recent IRS guidance and administrative issuances, relevant ...
Business advisers can help guide clients through the tax and accounting considerations of a corporate sale or purchase.
The Tax Court found a regulation invalid to the extent it holds the period open for the IRS to issue a final partnership adjustment longer than the statutory 270 days after a partnership has submitted ...