The Tax Adviser

IRS Practice & Procedure

In a letter to Treasury and the IRS, the AICPA seeks changes to tax reporting requirements for partnerships and S corporations. The IRS released initial details on Trump accounts, a new type of IRA ...
The Tax Adviser

S Corporation Income Taxation

In a letter to Treasury and the IRS, the AICPA seeks changes to tax reporting requirements for partnerships and S corporations. The IRS may grant a reasonable extension if the taxpayer provides ...
The Tax Adviser

Partnership and LLC Taxation

In a letter to Treasury and the IRS, the AICPA seeks changes to tax reporting requirements for partnerships and S corporations. In Soroban Capital Partners, the Tax Court analyzed the roles, ...
The Tax Adviser

Practice Management & Professional Standards

A well-drafted engagement letter provides essential protection and important benefits to CPAs in tax practice and in other engagements and to their clients. In their reasonable reliance on software ...
The Tax Adviser

Two Tax Court rulings expose overvalued conservation easements

In the cases, the Tax Court determined the value of a conservation easement donated to charity using the comparable sales method instead of the discounted-cash-flow method.
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

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 Adviser

Employment tax penalties: Let’s keep it civil

Many practitioners who counsel business clients, both small and large, are familiar with the difficult challenges that quickly arise when taxes are withheld from employee wages but not turned over to ...
The Tax Adviser

Loans between members and LLCs

An advance of money by a member to a limited liability company (LLC) classified as a partnership may be in the form of a capital contribution or a loan. This distinction has significant tax ...
The Tax Adviser

The grantor trust rules: An exploited mismatch

A mismatch in determining whether a transfer is complete under the income tax regime on the one hand and the transfer tax regime on the other creates what could be considered an estate planning ...