The new safe-harbor guidance for digital asset transaction reporting in Rev. Proc. 2024-28 goes into effect Jan. 1, 2025. This article explains how taxpayers may rely on the safe harbor to allocate ...

Q Are CPAs offering Corporate Transparency Act filing services? A Many CPA firms now offer Corporate Transparency Act filing services. Initially, in early 2024, there was hesitation due to practice-of ...

The regulations terminate the continued application of the Sec. 367(d) annual inclusion in certain cases when intangible property is repatriated to the United States after previously being transferred ...

The regulations terminate the continued application of the Sec. 367(d) annual inclusion in certain cases when intangible property is repatriated to the United States after previously being transferred ...

The regulations terminate the continued application of the Sec. 367(d) annual inclusion in certain cases when intangible property is repatriated to the United States after previously being transferred ...

Taxpayers should consider tax planning issues for partnerships and their partners when raising capital and exchanging debt for equity. U.S. persons owning an interest in a foreign partnership may be ...

A recent Tax Court case sheds light on the uncertainty test for qualified research activities and its relation to the adaptation exclusion of expenditures eligible for the Sec. 41 research credit.

The IRS issued guidance for recipients of property from decedents on the basis-consistency requirement and for executors and others on basis-reporting requirements. The IRS said that crowdfunding ...

The IRS issued guidance for recipients of property from decedents on the basis-consistency requirement and for executors and others on basis-reporting requirements. The IRS said that crowdfunding ...

The Service said it will release new proposed regulations and a revenue ruling to challenge the use of basis-shifting transactions used by complex partnerships in moves that could add over $50 billion ...