- Taxpayer may not deduct penalties imposed for violating a law
- Ensuring that shareholder debt is not reclassified as equity
- Basket contracts would be listed transactions under proposed regs.
- Treasury provides guidance on the interaction of DCLs with Pillar Two taxes
- Profits interests: The most tax-efficient equity grant to employees
- Proposed regulations update QDOT regulations
- Seller beware: Repossessions in real estate installment transactions
- Arthur J. Dixon Memorial and Jonathan Horn Distinguished Service awards
- Strategies for information return penalties and Form 945 assessments
- Automatic consent to Sec. 174 accounting method changes modified
- IRS FAQ clarifies sunset of Notice 2010-46 credit forward framework
- No Collection Due Process hearing for FBAR penalties
- Using the IRS’s BBA Online Form Submission Service
- New prop. regs. limit taxpayers’ foreign currency elections
- Expenses that could have been substantiated not allowed
