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

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.

Under Regs. Sec. 1.987-15, the 2024 final regulations generally apply to tax years beginning after Dec. 31, 2024, as ...

Determining when energy property is eligible for a tax credit or deduction hinges on when it is first placed in service, which can be controversial.

Another item for U.S. inpatriates to consider is potentially having to pay taxes on foreign currency gain when they pay off their non – U .S. mortgage. If an individual pays off a non – U .S. mortgage ...

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 ...

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 ...

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 ...