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

The Tax Adviser—the magazine of planning, trends, and techniques—reports and explains federal tax issues to tax practitioners.

The Tax Adviser—the magazine of planning, trends, and techniques—reports and explains federal tax issues to tax practitioners.

The evolving demands of the accounting profession reflect a need for graduates to possess a diverse set of skills, including personal financial planning (PFP). Accordingly, PFP topics now appear on ...

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 ...

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 ...

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 ...

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 ...

In proposed regulations issued in September 1991 (56 Fed. Reg. 48457), Treasury and the IRS conceived of an earnings and capital method of accounting for Sec. 987 gain or loss. From the outset, the ...

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 ...

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, ...

Investors looking for greater diversification and opportunity often invest in partnerships to access private equity and other investments unavailable to the public. Further, these partnerships often ...