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New final regulations pose significant implications for possible income inclusions by U.S. corporations with foreign ...
Under Regs. Sec. 1.987-15, the 2024 final regulations generally apply to tax years beginning after Dec. 31, 2024, as ...
Examining a personal financial planning scenario can help students develop the application and analysis skills necessary to ...
Properly established and maintained, an incomplete gift nongrantor trust may play a valuable role in some clients’ estate ...
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.
Sec. 541 imposes a 20% tax on the undistributed personal holding company income of a personal holding company. Initially ...
Further, these partnerships often invest in foreign entities. Many partners, especially limited partners, have no ability to direct the partnership’s operations and investment choices. Since foreign ...
Taxpayers may be subject to the risk that an IRS examination could increase (or create) a gift tax or estate tax liability many years after a gift is made. Practitioners can help clients limit this ...
Recent final regulations offer guidance as to what Treasury and the IRS may consider an eligible method for partnerships and Sec. 987 QBUs held by partnerships to determine Sec. 987 gain or loss.
Matthew Gotlin, CFA, MBA, Chief Investment Officer and Managing Director, Wealth Management, ChoreoMatt leads the firm’s ...
At $3,000 and never adjusted for inflation during nearly a century, the Sec. 861(a)(3) de minimis exception seldom applies.
Deferred revenue liabilities must be carefully considered in conjunction with taxable asset sales, contributions to capital, and classification elections.
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