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AI is transforming transfer pricing
Mimi Song, COO, Exactera, discusses how AI can improve transfer pricing compliance.
From practitioner to influencer: Managing the risks of online content for tax professionals
Practitioners must exercise awareness of how their tax-related social media and other online posts may implicate professional standards.
Practical considerations for taxpayers and advisers following Loper Bright and Corner Post
Taxpayers and advisers should reckon with the two Supreme Court decisions when evaluating tax return positions that may conflict with existing administrative guidance.
State compliance for multitiered partnerships: Planning, communication, and execution can avoid common mistakes
Strategic planning and proactive compliance are key to fulfilling these often complex filing requirements across multiple jurisdictions.
Results of recent academic research may aid practitioner planning
Five tax research articles published in the past year in academic journals provide potentially valuable insights for practitioners.
Tax Court addresses dueling motions to dismiss
The court granted the IRS’s motion because the petition was untimely and denied the taxpayer’s contending that the Service’s deficiency notices were invalid.
The role of REITs for foreign investors in US real estate
Foreign investors with U.S. real property interests seeking to reduce their tax burden may find real estate investment trusts useful.
IC-DISC commission payment provisions
Interest charge domestic international sales corporations offer tax benefits, but taxpayers must carefully follow their requirements.
Are you doing all you can to keep the cash method for your clients?
A passthrough entity business cannot use the cash method of accounting if it is classified as a syndicate. This article discusses this rule and ways a passthrough entity business that is currently not a syndicate can avoid being reclassified as one and losing the use of the cash method.
Qualified small business stock: The trap for foreign entities restructuring into a US corporation
A common cross-border reorganization can doom eligibility for the valuable gain exclusion without thoughtful planning.
IRS clarifies that Appeals case memos should be shared with taxpayers upon request
National Taxpayer Advocate Erin Collins wrote Tuesday in her blog that the IRS reminder of the language in the Internal Revenue Manual is a “meaningful step toward transparency.”
Current developments in S corporations
This annual update covers recent developments relating to S corporations, including IRS relief for common inadvertent S election lapses; the transfer of clean-energy credits; and other cases, rulings, and regulations.
Paid student-athletes: Tax implications for universities and donors
The taxation of Division I college sports may change once universities begin paying athletes directly, which will be permitted under a settlement of antitrust litigation against the NCAA and major collegiate athletic conferences. This article discusses some of the yet-to-be-resolved tax issues for schools and donors.
A transfer pricing paradox: High-risk transactions remain underrepresented in APAs
Intangible property transactions are a minority of those covered by advance pricing agreements, despite their generally high risk for taxpayers.
Complying with ACA tax-exempt hospital requirements
Hospital facilities must meet the requirements of Sec. 501(r) provisions of the Patient Protection and Affordable Care Act, P.L. 111-148 to retain tax-exempt status.
The enduring importance of determining tax ownership
Throughout nearly a century of case law and guidance, the benefits and burdens of ownership have remained the touchstone for claiming tax attributes of tangible property.
Amended returns and the Sec. 965(k) six-year period for assessment
A Joint Committee on Taxation report’s language raises questions about the running of the statute of limitation for liability for the Sec. 965 transition tax.
5 things to know about tax relief for federal disasters
While the IRS has discretion to provide relief, Sec. 7508A(d) provides a mandatory tax deadline postponement. In either case, the ‘lookback’ limitation period for refunds remains a concern.
Tax ethical challenges when representing taxpayers
AICPA members providing tax representation or return preparation services need to comply with both the AICPA Statements on Standards for Tax Services and Treasury Circular 230.
It’s no joke: Being nice is among this attorney’s top ways to deal with the IRS
Being nice is one of tax controversy attorney Melissa Wiley’s ways of getting answers from the IRS, which also includes knowing the Internal Revenue Manual and using self-service tools.
