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Refund dead ends: Statute-of-limitation considerations
Practitioners must observe and protect time limits for requesting a refund, administrative appeals, and
litigation.
Current developments in S corporations
This annual update covers recent developments, including court cases and selected administrative changes occurring in the 12 months ending March 2026.
Taxpayers’ rights and the IRM: Part 1
Acquaintance with relevant Internal Revenue Manual provisions can aid practitioners in protecting clients’ rights in tax controversies.
Tax Court addresses disallowance of DRD and FTC
Tax Court disallows part of a taxpayer’s Sec. 245A dividends-received deduction and holds post–Sec. 965(c) amount must be included in formula to determine Sec. 245A(d)(1) foreign tax credit disallowance.
Transfer pricing treatment of acquired intangibles
After a cross-border merger or acquisition, related affiliates often integrate and use the acquired intangibles, such as new products or innovative features. To help executives manage the resulting transfer pricing risk, this article examines the treatment of acquired intangibles in post-acquisition related-party transactions.
Tax planning for exchange-traded funds
Besides allowing investors to conveniently spread risk within a sector, ETFs can help in avoiding wash-sale treatment.
Planning for domestication transactions
Foreign companies can realize benefits from establishing domicile in the United States if they observe structural and special rules and considerations.
Effect of the new pro rata share rules
Even though recent changes substantially reduced abuse concerns, U.S. corporate shareholders must still comply with the extraordinary reduction rules when deducting certain foreign dividends.
FIRPTA considerations for power and energy investments
The Foreign Investment in Real Property Tax Act may be triggered when a foreign investor invests in a U.S. data center or an independent power producer.
FinCEN director expects final BOI reporting rule soon
The director of the Financial Crimes Enforcement Network told a congressional subcommittee that she’s “very optimistic” that the final rule will be issued before the end of the year.
Tax implications of US residency for foreign nationals
Foreign entrepreneurs and others entering the United States, whether for short-term visits or permanently, should be mindful of the complex U.S. income tax and foreign information-reporting rules that may apply to them.
IRS raises standard mileage rates for remainder of 2026
The midyear change follows an increase in gasoline prices, according to the IRS. It is the first such midyear adjustment since 2022.
The new CFC tax landscape after OBBBA
H.R. 1, P.L. 119-21, known as the One Big Beautiful Bill Act, introduced significant changes to the controlled foreign corporation rules that affect U.S. taxpayers with foreign corporate interests. Two key amendments introduced under Section 70353 of the OBBBA are particularly noteworthy.
Eligible taxpayers to get automatic IRS penalty relief
Under the new system, eligible taxpayers will no longer have to request penalty relief that the IRS says is routinely granted.
State tax history at the United States’ 250th anniversary
Read (and test your knowledge) regarding the origins and evolution of state taxing authority on the eve of this milestone.
R&D credits and the computer rental rules time forgot
Although computing has transformed radically in the past 45 years, the computer rental rules of Sec. 41 and regulations continue to reflect technology as it existed 1980s.
Fuel tax expirations and new refund provisions require IRS guidance and improved administration
With major fuel tax provisions expiring, the upcoming change to electronic payments, refunds for federal excise taxes, and the IRS excise tax hotline remaining unstaffed, taxpayers are facing a period of unusual uncertainty for federal excise taxes.
VAT challenges in AI product development
Artificial intelligence may incrementally become a product’s component until it crosses a threshold into being a digital service subject to value-added tax.
Rethinking burnout boundaries and client fit
Members of the AICPA Tax Practice Management Committee share their strategies for addressing staff stress and burnout, including finding the courage to disengage from problem clients.
The historic shift in transfer pricing penalty enforcement
Once rarely imposed, transfer pricing penalties are now a routine feature of IRS examinations, making the quality of transfer pricing documentation more important than ever.
