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

New final regulations pose significant implications for possible income inclusions by U.S. corporations with foreign ...

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 ...

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 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 ...

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 ...

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 ...

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 ...

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 ...

Sec. 541 imposes a 20% tax on the undistributed personal holding company income of a personal holding company. Initially enacted in 1934, the tax was intended to discourage individuals from using ...

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 ...