Determining the appropriate tax treatment of an investment fund’s waived management fee involves a number of factors, the ...

With enhanced Sec. 1202 gain exclusion, permanency of Sec. 199A, and other provisions, the calculus for entity choice has ...

High‑net‑worth families can preserve wealth across generations by pairing intentionally defective grantor trusts with ...

A variety of capitalization strategies can increase deductible interest expense now that depreciation, amortization, and ...

Before adopting the newly reinstated expensing of research and experimental expenditures, taxpayers should first consider the ...

Proactive management of net unrealized built-in losses in ownership changes is increasingly important in today’s volatile ...

A foreign employer’s duty to comply with U.S. payroll tax rules for employees who work in the United States can give rise to ...

This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance ...

Sec. 1202 offers a compelling tax benefit: exclusion of up to 100% of the gain from the sale of qualified small business stock (QSBS) that has been held for at least five years. For eligible taxpayers ...

The purpose of Sec. 2702 is to determine whether a transfer after Oct. 8, 1990, of an interest in a trust to a family member is a gift and, if so, the value of the gift. A family member includes (1) ...

The table “1. Sample Rate Analysis” illustrates the interaction of jurisdictional income taxes assuming a domestic, U.S.-domiciled PBE that apportions 100% of its income to one state. The United ...