Tax shelters generally follow the letter of the Internal Revenue Code but produce results that the Code never intended, such as tax losses that offset a taxpayer's capital gains or other income, often with minimal costs to the taxpayer. READ NOW » ...
With the IRS announcing the 2023 cost-of-living-adjusted limits that apply to qualified plans in Notice 2022-55 , notably, the new 401(k) elective deferral limit rising 10% (to $22,500), now is a good time for 401(k) plan sponsors to remind participants not only...
In addition to the work tax and accounting departments may have to establish federal and state withholding and reporting for their employees, employers have to comply with special state reporting for new hires and rehires to comport with the Personal Responsibility...
One headache you don’t need is having the IRS audit your client for internal worker misclassifications. Although employers often reap financial benefits when they classify workers as independent contractors, they could face substantial liability if they misclassify...
When evaluating the accounting consequences of tax credits, an entity needs to consider the underlying characteristics of the credit, the entity's intent for utilizing or transferring the credit, and determine if accounting policies have been previously established...
The Inflation Reduction Act significantly increased funding for the IRS, much of which goes to IRS enforcement efforts. In particular, the IRA appropriated $45.6 billion for enforcement, available until September 30, 2031. READ NOW » Related Content ...
Attorneys are not necessarily trained in the language of financial reporting, however, when consulting on a tax issue for a company, it is important to understand the interplay between a company’s financial statement reporting and its tax reporting. READ...
Whether you’re in need of a refresher or are learning the area of consolidated tax returns for the first time, the Federal Income Taxation of Corporations Filing Consolidated Returns (2d ed.) treatise is a valuable resource for the information you need. Practical...
As cryptocurrency has grown quickly, tax administrations worldwide have had to address the tax and regulatory issues presented by the new financial landscape, and tax practitioners should keep a careful eye on current developments when advising clients. Read...
The Inflation Reduction Act of 2022, Pub. L. No. 117-169, 136 Stat. 1818 (2022) (IRA), signed into law on August 16, 2022, primarily funds energy security and climate change activities. Because the IRA states that it generates more revenue than it spends, the IRA...
Review the fundamentals of the global intangible low-tax income (GILTI) and the foreign-derived intangible income (FDII) tax regimes. GILTI and FDII were both created by the Tax Cuts and Jobs Act of 2017 (TCJA). Pub. L. No. 115-97 . The TCJA enacted I.R.C. Section...
Although a majority of tax disputes are resolved by agreement or administrative settlement, sometimes taxpayers are unable to settle claims with the IRS through examination, the IRS Office of Appeals, or various alternative dispute resolution techniques. They then...
In the news is “carried interest”, which is taxed at a lower 20% capital gains rate, rather than the top 37% marginal tax rate that applies to ordinary income. The special rate on carried interest owes its continued existence in the tax code to Arizona...
A disguised sale occurs when a partner intentionally "contributes" property with a built-in gain to a partnership and immediately, or shortly thereafter, receives a related "distribution." While a contribution and distribution would normally...
Before the Dobbs v. Jackson Women’s Health Organization decision, costs related to an abortion procedure would (if the account were sufficient) be reimbursable under a Health FSA, an HRA, or an HSA (assuming the terms of the plan covered such costs) and treated...