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October 2019 - The Tax Adviser

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  2. October 2019
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ESTATES, TRUSTS & GIFTS

Recent developments in estate planning: Part 1

This article is the first of two parts of an annual update on developments in trust, estate, and gift taxation. Part 1 discusses developments affecting trusts and the generation-skipping transfer tax, as well as inflation adjustments.

TAX CLINIC

expenses & deductions

IRS releases guidance on treatment of transaction costs

FOREIGN INCOME & TAXPAYERS

Demystifying the new international E&P rules

The TCJA: Double taxation for US citizens living abroad

GAINS & LOSSES

Like-kind exchanges and personal property

INTEREST INCOME & EXPENSE

Traversing Sec. 163(j) aggregation for affiliated service groups

partners & partnerships

New withholding regime on transfers of partnership interests

Phantom equity vs. profit interests: Strategic considerations

STATE & LOCAL TAXES

US MNCs facing implications of economic (vs. physical) nexus

Wayfair’s impact on not-for-profit purchases and revenues

COLUMNS

NEWS NOTES

Donor reporting changes violate the Administrative Procedure Act

IRS allows taxpayers to change their minds on bonus depreciation

Taxpayer First Act provision prompts IRS to change its third-party contact procedures

DC CURRENTS

Taxpayer First Act changes the dynamic between IRS and practitioners

TAX PRACTICE & PROCEDURES

Substitute-for-returns procedure

Pitfalls and treasures of the QBI deduction

IRS practitioner services and AICPA’s ongoing advocacy for improvement

CASE STUDY

Partnership terminations triggered by a change in form

TAX TRENDS

Reliance on preparer is not reasonable cause for late filing

INDIVIDUALS

Current Developments in Taxation of Individuals: Part 1

This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.

Tax Clinic

Planning for domestication transactions

Planning for new charitable contribution limits

Effect of the new pro rata share rules

Determining when a debt instrument has zero basis

Structuring partnership mergers