Results for "international"
Sort By
COVID-19 disaster relief case has implications for timely refund claims
National Taxpayer Advocate Erin Collins explained what affected taxpayers need to do in response to the Court of Federal Claims’ holding that a taxpayer’s refund claim filing deadline was automatically extended by Sec. 7508A(d)(1) due to the COVID-19 disaster declaration.
Demystifying reattribution: Disregarded payments and the FTC limitation
Adjustments under the disregarded-payment and foreign tax credit rules are often overlooked. This practical framework includes a step-by-step guide and example.
Unlocking efficiency and reducing risk: How automation and AI are transforming tax reporting and withholding functions
Taxing authorities’ use of these new tools and capabilities requires corresponding adoption by tax professionals.
Navigating tax controversy strategies amid IRS operational challenges
Practitioners must leverage available technology, build effective communication strategies, and maintain comprehensive documentation of their interactions with the Service.
Tax ethical standards in data protection and reliance on tools
Case studies illustrate provisions for safeguarding client data and outline professional responsibilities under the AICPA Statements on Standards for Tax Services.
Frequently encountered controversy issues in M&A transactions
Procedural issues involving entity change in mergers and acquisitions can be managed by attentiveness and, in many cases, relief provisions.
Fifth Circuit rejects ‘passive-investor’ definition of limited partner
The Fifth Circuit, overruling the Tax Court, held that for purposes of the Sec. 1402(a)(13) exclusion from self-employment tax, “limited partner” means a partner in a limited partnership that has limited liability.
Assessment of tax for excess APTC payments is invalid
The Tax Court advised a taxpayer that filing a second petition would not allow another IRS Collection Due Process review.
Does an EIN/name mismatch invalidate a refund claim?
Arguments using the ‘informal claim doctrine’ and/or a taxpayer assistance order with the Taxpayer Advocacy Service may help taxpayers whose refund claims are stymied by a mismatch caused by an incorrect employer identification number.
Hedge funds: Tax structuring, planning, and compliance
Hedge funds may face tax issues of entity structuring, carried interest, management fee waivers, and trading-related rules. This article highlights planning strategies and compliance considerations as the IRS continues to increase its scrutiny of these investment vehicles.
IRS’s rejection of marijuana dispensary’s offer in compromise upheld
A marijuana dispensary’s expenses not deductible under Sec. 280E are not taken into account in calculating its reasonable collection potential.
Sec. 174: The OBBBA and growing state tax disconformity
State conformity or decoupling from Sec. 174 and new Sec. 174A, enacted by the law known as the One Big Beautiful Bill Act, complicates the treatment of research and experimental expenditures.
Case study: Cross-border planning for an Australia-bound expatriate couple
Financial concerns of expatriating taxpayers include not only US taxes but also the relevant laws of the destination country.
Dissolving business taxpayers: Selected procedural implications
Critical issues include marking returns as final, determining due dates for final returns, filing Form 966, closing IRS accounts, and handling audits of dissolved entities.
Inside the pressure cooker: Taking care of yourself and your team during tax season
Tax season’s challenges can be overcome with leaders’ empathy and respect for team members.
IRS watchdog cites resource limits, duplication in partnership audits
The Treasury Inspector General for Tax Administration assessed a soft-letter initiative and the IRS’s examinations of 82 major U.S. partnerships.
AICPA pushes IRS to ease and expand first‑time abatement rules
The recommendations include allowing taxpayers to rely on substitute reasonable cause when appropriate, permitting them to reserve the automatic first-time abatement for future use.
IRS issues guidance on treaty application to reverse foreign hybrids
The IRS provides guidance on whether these entities qualify under a U.S. federal income tax treaty for relief from the branch profits tax.
When is a QSub election considered timely filed?
An F reorganization may raise a host of issues pertaining to timely filing of a qualified Subchapter S subsidiary election.
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.
