The Tax Adviser10 天
Transfer pricing: The C-suite needs to be informed
CEOs need to understand the arm’s-length rules for transactions between commonly controlled entities because of the enormous ...
The Tax Adviser10 天
On DRD, the IRS seeks to have its cake and eat it too
The plain language of Sec. 245A disallowed a dividends-received deduction for a controlled foreign corporation, the IRS ...
The Tax Adviser3 天
AICPA applauds Treasury's suspension of BOI enforcement
The AICPA said Treasury is "headed in the right direction" by suspending enforcement of beneficial ownership information (BOI) reporting requirements and urged it to extend reporting deadlines to at ...
The Tax Adviser10 天
Payments for law violation are not deductible restitution
A recent Chief Counsel Advice memo determined that the deductions were disallowed as fines or penalties under Sec. 162(f).
The Tax Adviser10 天
New IRS form for partners receiving property distributions
Form 7217, Partner’s Report of Property Distributed by a Partnership, debuted for 2024, intended to apprise the IRS of factors in a partner’s basis computation.
The Tax Adviser10 天
Mandatory basis adjustments for certain LLC transfers
The partnership-level adjustment may be required for a substantial built-in loss, except for electing investment partnerships and securitization partnerships.
The Tax Adviser10 天
States continue to tweak NOL provisions
In response to federal changes to net operating losses (NOLs) and fluctuating fiscal conditions, several states have recently enacted noteworthy legislation that changes the amount of state NOL ...