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The Tax Adviser1d
ING trusts: How they work and their continued viability
Properly established and maintained, an incomplete gift nongrantor trust may play a valuable role in some clients’ estate ...
The Tax Adviser1d
Integrating personal financial planning into individual income tax courses
Examining a personal financial planning scenario can help students develop the application and analysis skills necessary to ...
The Tax Adviser1d
Sec. 541: A trap for the unwary investment partnership
Sec. 541 imposes a 20% tax on the undistributed personal holding company income of a personal holding company. Initially ...
The Tax Adviser1d
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 Adviser1d
Sec. 987 final regulations: A practical approach for partnerships
Recent final regulations offer guidance as to what Treasury and the IRS may consider an eligible method for partnerships and Sec. 987 QBUs held by partnerships to determine Sec. 987 gain or loss.
The Tax Adviser1d
Tax planning for inpatriates
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 ...
The Tax Adviser1d
‘Looking through’ income tax apportionment for service providers
The state’s CAT regulations specifically provide that if health care services are performed in Ohio, 100% of the gross receipts are sourced there. If a health care service is provided partly in and ...
The Tax Adviser1d
Why non-US directors can rarely exempt US-source compensation from US income tax
At $3,000 and never adjusted for inflation during nearly a century, the Sec. 861(a)(3) de minimis exception seldom applies.
The Tax Adviser1d
Deferred revenue: Transactional triggering events
Deferred revenue liabilities must be carefully considered in conjunction with taxable asset sales, contributions to capital, and classification elections.
The Tax Adviser1d
Court allows Sec. 7431 tax information disclosure claim to go forward
The court refused to dismiss a taxpayer’s claim under Sec. 7431 against a company that employed an individual who made an unauthorized disclosure of the taxpayer’s tax return and information.
The Tax Adviser1d
Partnership reporting of contributions to foreign entities
Further, these partnerships often invest in foreign entities. Many partners, especially limited partners, have no ability to direct the partnership’s operations and investment choices. Since foreign ...
The Tax Adviser1d
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 ...