The new safe-harbor guidance for digital asset transaction reporting in Rev. Proc. 2024-28 goes into effect Jan. 1, 2025. This article explains how taxpayers may rely on the safe harbor to allocate ...

In addition to the guidance on the plan, the letter recommends that Treasury and the IRS continue pursuing tax simplification. IRS commissioner Danny Werfel promised “marked improvement” for the ...

A recent Tax Court case sheds light on the uncertainty test for qualified research activities and its relation to the adaptation exclusion of expenditures eligible for the Sec. 41 research credit.

Editor: Albert B. Ellentuck, Esq. Under Sec. 119(a), meals provided by an employer—including a C corporation employer—can be excluded from an employee’s gross income if they are furnished on the ...

The new schedules for returns of passthrough entities with international items have been greeted with antipathy by practitioners. The IRS provided relief Wednesday for eligible entities for tax year ...

Regulations explicitly require elections to be made by the corporation, and shareholders themselves cannot change these elections. Because facade easements must be protected in perpetuity, a ...

The IRS issued guidance for recipients of property from decedents on the basis-consistency requirement and for executors and others on basis-reporting requirements. The IRS said that crowdfunding ...

The regulations terminate the continued application of the Sec. 367(d) annual inclusion in certain cases when intangible property is repatriated to the United States after previously being transferred ...

A number of disqualifying events can terminate a corporation’s S status, and not all of those events are listed in the statute or immediately obvious.

The Financial Crimes Enforcement Network extended filing deadlines for reports of foreign bank and financial accounts (FBAR) for people in federally declared disaster areas of five storms. It also is ...

The IRS issued a notice on regarding the application of the corporate alternative minimum tax to shareholders of CFCs and to affiliated groups of corporations filing consolidated returns.

This first part of this annual update focuses on trust and gift tax issues. The penalty for failure to report a distribution from a foreign trust is not reduced when the trust beneficiary is also the ...