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

Under Regs. Sec. 1.987-15, the 2024 final regulations generally apply to tax years beginning after Dec. 31, 2024, as ...

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 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 ...

Each year, tax professionals who deal with real estate must evaluate the most recent building expenditures and determine which items should be deducted as a repair expense or capitalized. Of all the ...

Editor: Rochelle Hodes, J.D., LL.M. Expatriation is a major life decision with big tax implications for anybody thinking about giving up their U.S. citizenship or long-term permanent resident status.

Taxpayers generally must capitalize amounts paid to improve a unit of property. A unit of property is improved if the cost is made for (1) a betterment to the unit of property; (2) a restoration of ...

The Fifth Circuit’s decision in Grigsby, 86 F.4th 602 (5th Cir. 2023), emphasizes the need for taxpayers to clearly define business components when preparing and documenting their Sec. 41 credit. It ...

Planning with revocable trusts has become increasingly popular in recent years. In many instances, the motives for using a revocable trust are nontax and include avoiding probate, asset protection ...

Determining when energy property is eligible for a tax credit or deduction hinges on when it is first placed in service, which can be controversial.

The IRS may apply the step-transaction doctrine, a rule of substance over form, in a variety of taxpayer circumstances to deny tax benefits derived from a series of transactions that should more ...

Congress has provided a variety of incentives to encourage taxpayers to invest in small businesses. In the past several years, Congress has made these incentives more generous, to the point where a ...