The Tax Adviser

Current developments in S corporations

Sec. 1361 sets forth the basic qualifications for S corporation status. Among the most important are the limitation on types of shareholders and restrictions to a single class of stock. Tax Court ...
The Tax Adviser

Global expansion of e-invoicing and digital reporting obligations for nonresidents

Editor: Mary Van Leuven, J.D., LL.M. Mary Van Leuven, J.D., LL.M., is a director, Washington National Tax, at KPMG LLP in Washington, D.C. For additional information ...
The Tax Adviser

Disregarded-payment-loss rules: How multinationals should prepare

Treasury and the IRS on Jan. 10, 2025, released final regulations regarding dual-consolidated-loss (DCL) and disregarded-payment-loss (DPL) rules (T.D. 10026). These finalize proposed regulations ...
The Tax Adviser

Tax accounting method changes: Procedures and potential issues during an IRS exam

A threshold matter for determining the proper procedure during an exam is whether a potentially identified issue is an accounting method (a timing issue, as discussed ...
The Tax Adviser

ING trusts: How they work and their continued viability

In the context of trusts, CPAs may have heard someone mention WINGs, DINGs, or NINGs. This article aims to explain the advantages, requirements, and potential drawbacks of these trusts for estate ...
The Tax Adviser

How S elections go wrong and how to fix them

To be an S corporation is to live dangerously. After all, in order to be taxed as an S corporation, the corporation 1 must file a complete and timely election with the IRS and meet and maintain strict ...
The Tax Adviser

Elections under the new Sec. 987 final regs.

For taxpayers that have a qualified business unit (QBU) with a functional currency other than the dollar, Sec. 987 provides rules on how to adjust for changes in exchange rates. On Dec. 10, 2024, ...
The Tax Adviser

Legacy clean-energy credits evolve into tech-neutral credits

Editor: Mo Bell-Jacobs, J.D. Federal income tax credits have been used to incentivize investment in clean–energy projects for decades. The Sec. 48 energy credit is a component of the Sec. 46 ...
The Tax Adviser

Taxation of undocumented immigrants

Undocumented immigrants venture to the United States from all parts of the world and endure enormous challenges in their new life, ranging from cultural ones to those that are language–oriented in ...
The Tax Adviser

Tax considerations for foreign investment in US private credit

Private credit as an asset class has undeniably seen tremendous growth over the last two decades. Since 2007, private credit has expanded by more than 10 times, and most large asset managers and ...
The Tax Adviser

Shareholder Transactions

The IRS issued proposed regulations providing guidance on the corporate alternative minimum tax (AMT) and a notice that waives the penalty for failure to pay estimated tax with respect to the ...
The Tax Adviser

The self-rental rules: Risks and opportunities

The COVID-19 pandemic ushered in erratic price behavior for commercial real estate, with many markets quickly reaching new highs and others experiencing declines. The Federal Reserve’s Commercial Real ...