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

Paid student-athletes: Tax implications for universities and donors

In a recent development following a series of legal actions, e.g., House v. NCAA 5 and Carter v. NCAA, 6 a settlement agreement was reached between the college sport stakeholders, including the NCAA, ...
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

Clean fuel production credit: Regulatory roadblocks ahead

Editor: Mary Van Leuven, J.D., LL.M. This item explores two key issues among many that are puzzling industry participants: imported used cooking oil (UCO) and the definition of a qualifying sale, ...
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

Why non-US directors can rarely exempt US-source compensation from US income tax

The nonresident alien performing the services is present in the United States during the tax year for fewer than 90 days in the aggregate; The total compensation earned for services performed in the ...
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 ...
The Tax Adviser

Planning for the AMT

Individuals are subject to two income tax systems: the regular income tax and the alternative minimum tax (AMT). Taxpayers must compute their tax under each system and pay the greater of the two ...
The Tax Adviser

Transfer pricing: The C-suite needs to be informed

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, ...