The Tax Adviser

Managing tax practices in response to new legislation

Firms need to identify the planning opportunities in new legislation. Using H.R. 1 as an example, some of the provisions that affect tax planning and clients are: Again, using H.R. 1 as an example, ...
The Tax Adviser

Digital asset transactions: Broker reporting, amount realized, and basis

In December 2022, Treasury and the IRS stated that they intended to implement the Infrastructure Act amendments to the Code by issuing new regulations and providing forms and instructions for broker ...
The Tax Adviser

Planning with charitable remainder trusts

First, ordinary income and such undistributed income of the trust for prior years; Second, capital gain (including unrecaptured Sec. 1250 gain and gain on collectibles taxed at 28%) and such ...
The Tax Adviser

The role of REITs for foreign investors in US real estate

Editor: Robert Venables, CPA, J.D., LL.M. Foreign persons investing in U.S. real estate face unique tax complexities under the Internal Revenue Code. Navigating these complexities is crucial to ...
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

Microcaptive insurance arrangements subject to new rules

This article examines the final regulations governing microcaptive insurance arrangements and their effect on taxpayers and their advisers. For background, this article also provides an overview of ...
The Tax Adviser

Adequate disclosure on gift tax returns: A requirement for more than gifts

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 ...
The Tax Adviser

Deferred revenue: Transactional triggering events

Operating businesses in various industries often receive advance payments for goods or services that will be provided in the future, and the presence of deferred or unearned revenue in a balance sheet ...
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

Incentives for solar power generation systems

With a host of tax and incentive programs, there are many reasons for taxpayers to install solar power generation systems. The tax benefits can include income tax credits, breaks on local real estate ...
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 ...