PLR 202304008: Taxpayer Does Not Have Section 961(b)(2) Gain for Mid-Year Distributions -
Introduction to Section 961 and Mid-Year Distributions -
For years, there has been a longstanding question under the subpart F...more
The IRS has for the second time in as many years included monetized installment sales on its annual “Dirty Dozen” tax schemes list. As we discussed in a prior post, the “Dirty Dozen” list alerts taxpayers and practitioners to...more
Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure -
U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more
1/25/2023
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Corporate Structures ,
Corporate Taxes ,
FBAR ,
Foreign Corporations ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
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IRS Chief Counsel Memoranda: Cryptocurrency Donations Above $5,000 Need Qualified Appraisal and No Unrealized Cryptocurrency Loss Without Disposition -
Introduction -
The IRS recently released two chief counsel...more
Introduction: Consolidated Groups and Section 951(a)(2)(B) Tax Planning -
On December 9, 2022, Treasury and the IRS released proposed regulations that are intended to stop certain U.S. shareholder tax planning under...more
Eleventh Circuit Sides with Ninth Circuit on Section 6751(b) Circuit Split -
Introduction: Section 6751(b) and the Timing of Supervisory Approval of a Penalty -
The Eleventh Circuit’s decision in Kroner v. Commissioner,...more
12/14/2022
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Income Taxes ,
Internal Revenue Code (IRC) ,
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Tax Returns
GRAs and Section 367(a)(1) Outbound Stock Transfer Rules Overview - Introduction to Section 367(a)(1), Outbound Stock Transfers, and Gain Recognition Agreements - Section 367(a) of the Internal Revenue Code (the “Code”)...more