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The Tax Adviser6d
Management Accounting
The Tax Adviser—the magazine of planning, trends, and techniques—reports and explains federal tax issues to tax practitioners.
The Tax Adviser7d
Using transfer pricing to blunt the effects of tariffs
Understanding the interrelationship of transfer pricing and tariffs is key to mitigating the effect of those levies on ...
The Tax Adviser15d
Disregarded-payment-loss rules: How multinationals should prepare
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 ...
The Tax Adviser18d
Tax accounting method changes: Procedures and potential issues during an IRS exam
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 Tax Adviser18d
ING trusts: How they work and their continued viability
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 ...
The Tax Adviser18d
Sec. 987 final regulations: A practical approach for partnerships
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 Tax Adviser18d
Integrating personal financial planning into individual income tax courses
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 ...
The Tax Adviser18d
How S elections go wrong and how to fix them
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 Tax Adviser18d
Why non-US directors can rarely exempt US-source compensation from US income tax
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 ...
The Tax Adviser18d
Adequate disclosure on gift tax returns: A requirement for more than gifts
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 ...
The Tax Adviser18d
Partnership reporting of contributions to foreign entities
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 Tax Adviser18d
Tax planning for health care management services organizations
In the rapidly evolving health care industry, organizational structures often include management services organizations (MSOs) to set apart clinical and nonclinical activities. The purpose of an MSO ...