The Tax Adviser—the magazine of planning, trends, and techniques—reports and explains federal tax issues to tax practitioners.

The Tax Adviser—the magazine of planning, trends, and techniques—reports and explains federal tax issues to tax practitioners.

Understanding the interrelationship of transfer pricing and tariffs is key to mitigating the effect of those levies on ...

New final regulations pose significant implications for possible income inclusions by U.S. corporations with foreign ...

Another item for U.S. inpatriates to consider is potentially having to pay taxes on foreign currency gain when they pay off their non – U .S. mortgage. If an individual pays off a non – U .S. mortgage ...

A threshold matter for determining the proper procedure during an exam is whether a potentially identified issue is an accounting method (a timing issue, as discussed ...

In the context of trusts, CPAs may have heard someone mention WINGs, DINGs, or NINGs. This article aims to explain the advantages, requirements, and potential drawbacks of these trusts for estate ...

To be an S corporation is to live dangerously. After all, in order to be taxed as an S corporation, the corporation 1 must file a complete and timely election with the IRS and meet and maintain strict ...

Taxpayers may be subject to the risk that an IRS examination could increase (or create) a gift tax or estate tax liability many years after a gift is made. Practitioners can help clients limit this ...

In proposed regulations issued in September 1991 (56 Fed. Reg. 48457), Treasury and the IRS conceived of an earnings and capital method of accounting for Sec. 987 gain or loss. From the outset, the ...

Investors looking for greater diversification and opportunity often invest in partnerships to access private equity and other investments unavailable to the public. Further, these partnerships often ...

Under Regs. Sec. 1.987-15, the 2024 final regulations generally apply to tax years beginning after Dec. 31, 2024, as ...