The Tax Adviser

IRS Practice & Procedure

The AICPA praised the Senate passage of the bill, saying it will enhance IRS operations and improve the taxpayer experience. The AICPA said taxpayers and tax professionals need certainty about how to ...
The Tax Adviser

Foreign financial asset filing requirements: Coming into compliance

On occasion, taxpayers holding investments in foreign financial assets or with foreign financial institutions may find themselves in the uncomfortable position of realizing that they have failed to ...
The Tax Adviser

Stock option planning: Generating value

Annually, millions of Americans are granted stock options by their employer. The majority of recipients are high-net-worth individuals (or soon will be). The positive impact of this wealth-creation ...
The Tax Adviser

Revocable trusts and the grantor’s death: Planning and pitfalls

Planning with revocable trusts has become increasingly popular in recent years. In many instances, the motives for using a revocable trust are nontax and include avoiding probate, asset protection ...
The Tax Adviser

The Long Arm of Community Property Laws

The impact of community property laws on a client’s tax situation can be unexpected and diverse. The fact that a tax adviser practices in one of the 41 common law (non–community property law) states ...
The Tax Adviser

Avoiding an accuracy-related penalty through the reasonable-cause exception

Whether a taxpayer is subject to an accuracy-related penalty due to an understatement of tax is the most-litigated tax issue in recent years. Although the IRS wins a large majority of cases on this ...
The Tax Adviser

Current developments in S corporations

Sec. 1361 sets forth the basic qualifications for S corporation status. Among the most important are the limitation on types of shareholders and restrictions to a single class of stock. Tax Court ...
The Tax Adviser

Sorting the tax consequences of settlements and judgments

During the normal course of business, a taxpayer may find itself the recipient or payer of a settlement or judgment as a result of litigation or arbitration. The federal tax implications of a ...
The Tax Adviser

The cost of deferred revenue

The legislation known as the Tax Cuts and Jobs Act (TCJA) 1 modified Sec. 451 to allow taxpayers to defer recognizing income until it is recognized in an applicable financial statement. 2 This rule ...
The Tax Adviser

Alert for IRAs holding master limited partnerships

Many clients have discovered, to their dismay, that holding master limited partnerships (MLP) inside an individual retirement account (IRA) or simplified employee pension individual retirement ...
The Tax Adviser

Reporting Trust and Estate Distributions to Foreign Beneficiaries (Part I)

As the world becomes more mobile, practitioners and fiduciaries must be familiar with international tax issues, including the complex withholding and reporting requirements that arise when U.S. trusts ...
The Tax Adviser

Conversion of a C corporation to an LLC

Only infrequently will it be beneficial for a C corporation to convert into a limited liability company (LLC). Although a conversion allows the C corporation shareholders to continue to have limited ...