Final regulations provide comprehensive guidance for tax reporting of transactions involving these increasingly common assets, and the IRS has granted transition relief in key areas.

In the cases, the Tax Court determined the value of a conservation easement donated to charity using the comparable sales method instead of the discounted-cash-flow method.

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 ...

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 ...

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 ...

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 ...

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 ...

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 ...

Editor: Mo Bell-Jacobs, J.D. Planning for NRND individuals with real estate is complex and requires a detailed review of applicable U.S. and state tax rules, treaties, and filing requirements to ...

In February 2024, the IRS announced it would be significantly increasing scrutiny of the use of noncommercial business aircraft by corporations, partnerships, and high–income taxpayers (e.g., business ...

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, ...

The basic rule for when a partner recognizes gain as a result of a distribution is found in Sec. 731(a)(1), which applies to both current distributions (from current income and activities) and ...