July 2022 - The Tax Adviser

Implications of legislative changes for R&E and software development costs

Gain recognition agreements: US corporation’s transfer of a foreign corporation followed by the foreign corporation’s disposition of its assets

Nonliquidating distributions: Ways to determine basis

A practical guide to partnership division planning

Interest claim limitation periods, including for ‘net rate’ netting claims

Sec. 451 regulations offer ways to reduce revenue acceleration

Passport revocation as a collection tool

Adequate disclosure and the IRS’s strategy of more information reporting

Foreign earned income exclusion: Pandemic-related relief

Tax consequences of real property foreclosures

Late-filed petition does not deprive Tax Court of jurisdiction over case

IRS litigators not bound by innocent-spouse determination