New final regulations pose significant implications for possible income inclusions by U.S. corporations with foreign ...

Understanding the interrelationship of transfer pricing and tariffs is key to mitigating the effect of those levies on ...

The Tax Adviser—the magazine of planning, trends, and techniques—reports and explains federal tax issues to tax practitioners.

The Tax Adviser—the magazine of planning, trends, and techniques—reports and explains federal tax issues to tax practitioners.

Problems with S elections frequently cause them to be invalid when made or to terminate. This article discusses four of the most common ones and three revenue procedures that may enable S corporations ...

A notice issued by the IRS with interim guidance for the application of the corporate alternative minimum tax offers an optional simplified method for determining applicable corporation status under ...

At $3,000 and never adjusted for inflation during nearly a century, the Sec. 861(a)(3) de minimis exception seldom applies. Recent final regulations offer guidance as to what Treasury and the IRS may ...

A letter from the AICPA and CPA societies in 53 states and jurisdictions criticizes the provision in the House version of the budget bill that would eliminate the state and local tax deduction for ...

Tax practitioners should be familiar with the special rules that apply and issues that can arise when an accounting method change is made while a taxpayer is under IRS examination. A foreign tax ...

To avoid contending with the complex and time-consuming calculations of the uniform capitalization rules under Sec. 263A, taxpayers may want to consider electing the historic absorption ratio with ...