The plain language of Sec. 245A disallowed a dividends-received deduction for a controlled foreign corporation, the IRS ...

Investors holding less than 10% of a controlled foreign corporation (CFC) are generally no longer shielded from double taxation under both the passive foreign investment company and CFC rules.

The AICPA said Treasury is "headed in the right direction" by suspending enforcement of beneficial ownership information (BOI) reporting requirements and urged it to extend reporting deadlines to at ...

Editor: Greg A. Fairbanks, J.D., LL.M. In response to federal changes to net operating losses (NOLs) and fluctuating fiscal conditions, several states have recently enacted noteworthy legislation that ...

A recent Chief Counsel Advice memo determined that the deductions were disallowed as fines or penalties under Sec. 162(f).

Regardless of whether a limited liability company (LLC) has a Sec. 754 election in effect, a partnership-level tax basis adjustment is required when an LLC interest is transferred (including a ...

For the most part, the CEOs of large multinational corporations (MNCs) do not need to know much about tax issues. CEOs are already busy, charged with developing a vision and strategy for growth, ...

The final regulations implement Sec. 2801, added to the Code in 2008, and follow up on proposed regulations issued 10 years ago. Changes to the qualified domestic trust regulations under Sec. 2056A ...

Editor: Greg A. Fairbanks, J.D., LL.M. The IRS released a draft form in summer 2024, with subsequent revisions and draft instructions, that partners will use, starting with tax years beginning in 2024 ...

To get through the rigors of tax season, CPAs depend on their tax preparation software. Here's how they rate the leading professional products.

Between November 2001 and September 2005, Raju Mukhi created three foreign entities, including Sukhmani Partners II Ltd., a foreign corporation for U.S. tax purposes. From 2002 through 2013, Mukhi did ...