Regardless of whether a limited liability company (LLC) has a Sec. 754 election in effect, a partnership-level tax basis adjustment is required when an LLC interest is transferred (including a ...

CEOs need to understand the arm’s-length rules for transactions between commonly controlled entities because of the enormous ...

Reconsidering its earlier holding in the case, the court again held the IRS lacks statutory authority to assess the penalties for failing to file information returns disclosing ownership in foreign ...

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 plain language of Sec. 245A disallowed a dividends-received deduction for a controlled foreign corporation, the IRS ...

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 changes the ...

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.

A recent Chief Counsel Advice memo determined that the deductions were disallowed as fines or penalties under Sec. 162(f).

Students role playing tax preparers and clients can thereby apply their tax knowledge interactively, inculcating critical real-world interpersonal skills.

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.