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February 2026 - The Tax Adviser

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PRACTICE MANAGEMENT

CPA firm M&A tax issues

Just as for other businesses, tax considerations come to the fore when CPA practices combine. This article delves into some of the possible entity deal structures for CPA firm mergers and acquisitions and the potential tax issues they present.

TAX CLINIC

expenses & deductions

Deductibility of transaction costs incurred by an indirectly acquired entity

FOREIGN INCOME & TAXPAYERS

IRS issues guidance on treaty application to reverse foreign hybrids

INTEREST INCOME & EXPENSE

IRS removes associated-property rule from interest capitalization regulations

MISCELLANEOUS

Practical tax issues related to qualified reopenings

partners & partnerships

Partner redemptions from ‘dry’ partnerships

S CORPORATIONS

When is a QSub election considered timely filed?

STATE & LOCAL TAXES

Pennsylvania Supreme Court invalidates Pittsburgh ‘jock tax’

COLUMNS

DIXON AND HORN AWARDS

Arthur J. Dixon Memorial and Jonathan Horn Distinguished Service awards

TAX PRACTICE RESPONSIBILITIES

Return preparer reliance on third-party tax advice

CAMPUS TO CLIENTS

Multistate corporate income taxes: An exercise in nexus and apportionment

CASE STUDY

Death of an LLC member: Basic tax considerations

TAX TRENDS

Penalties under codified economic substance doctrine upheld

Refund suit dismissed because Flora full-payment rule not met

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