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 ...
CEOs need to understand the arm’s-length rules for transactions between commonly controlled entities because of the enormous ...
Investors holding less than 10% of a controlled foreign corporation (CFC) are generally no longer shielded from double taxation under both the passive foreign investment company and CFC rules.
The plain language of Sec. 245A disallowed a dividends-received deduction for a controlled foreign corporation, the IRS ...
A recent Chief Counsel Advice memo determined that the deductions were disallowed as fines or penalties under Sec. 162(f).
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 Court focused on the taxpayer’s role as president and managing director of the company in which he invested, along with his failure to prove a theft occurred.
Students role playing tax preparers and clients can thereby apply their tax knowledge interactively, inculcating critical real-world interpersonal skills.
Editor: Greg A. Fairbanks, J.D., LL.M. In response to federal changes to net operating losses (NOLs) and fluctuating fiscal conditions, several states have recently enacted noteworthy legislation that ...
Between November 2001 and September 2005, Raju Mukhi created three foreign entities, including Sukhmani Partners II Ltd., a foreign corporation for U.S. tax purposes. From 2002 through 2013, Mukhi did ...