This article outlines a five-step process for calculating a corporate partner’s distributive share related to the application of the corporate alternative minimum tax imposed on an applicable ...
The new safe-harbor guidance for digital asset transaction reporting in Rev. Proc. 2024-28 goes into effect Jan. 1, 2025. This article explains how taxpayers may rely on the safe harbor to allocate ...
This first part of this annual update focuses on trust and gift tax issues. The penalty for failure to report a distribution from a foreign trust is not reduced when the trust beneficiary is also the ...
A personal service corporation must generally use a calendar year, but it can choose a fiscal year in certain circumstances.
Draft Form 706 instructions provide guidance for electing the portability of a deceased spouse’s unused estate tax exclusion amount and for the executor’s use of the check box to opt out of electing ...
A taxpayer, who received interests in four partnerships from his father by gift or bequest, did not step into his father’s shoes with respect to interest on certain partnership loans, A tax court ...
Taxpayers should consider tax planning issues for partnerships and their partners when raising capital and exchanging debt for equity. U.S. persons owning an interest in a foreign partnership may be ...
A limited liability company can elect to be classified as a corporation and elect S status by following the procedures discussed here. Review how shareholders would be taxed on the gain from the sale ...
The IRS issued guidance for recipients of property from decedents on the basis-consistency requirement and for executors and others on basis-reporting requirements. The IRS said that crowdfunding ...
The Sec. 737 rules can cause a member to recognize precontribution gain on contributed property where the value of property later distributed to that member exceeds their basis in the LLC. States vary ...