IRS: Basis Adjustments Apply to CFC Mid-Year Distributions to Prevent Section 961(b)(2) Gain
By Controlled Foreign Corporation (CFC), Cross-Border Tax Insights, International Tax, PLR, Subpart F
Mar 13, 2023
Tax Court in Brief | Estate of Spizzirri v. Commissioner | Gifts, Bequests, Deductible Expenses, and Estate Tax
By Estate Tax, Tax Court, The-Tax-Court-in-Brief Insights, Trust & Estate Litigation
Mar 10, 2023
Tax Court in Brief | Dawveed v. Comm’r | Restitution-Based Assessment and Collection Due Process
By Collection Due Process (CDP), Criminal, Tax Court, The-Tax-Court-in-Brief Insights
Mar 10, 2023
Tax Court in Brief | Estate of Kalikow v. Comm’r | Estate Tax Taxation and Deductions and QTIP Trust
By Settlements, Tax Court, The-Tax-Court-in-Brief Insights, Trusts
Mar 10, 2023
Taxpayers’ Failure to File Form 3520 and Form 3520-A Results in Extended Statute of Limitations Period: the Cautionary Tale of Fairbank
By Cross-Border Tax Insights, Form 3520, International Tax, IRS Collection, Tax Court, Trusts
Mar 03, 2023
Tax Court in Brief | Commonwealth Underwriting & Annuity Servs. v. Comm’r | Denial of Exemption Under IRC 501(c)(15)
By Tax Court, The-Tax-Court-in-Brief Insights
Mar 03, 2023
Department of Labor Issues Guidance on Religious Exemption Final Rule FAQs
By Non-Profit
Mar 01, 2023
The Collision of Title VII and Religious Freedom —The Aftermath of Bostock v. Clayton County for Religious Organizations
By Charitable Organization, Non-Profit
Feb 28, 2023
Tax Court in Brief | Moore v. Comm’r | Research Credit and Computation of Research Expenses under Section 41(a)
By Tax Court, The-Tax-Court-in-Brief Insights
Feb 24, 2023
Tax Court in Brief | Fairbank v. Comm’r | Reporting Obligations for Foreign Trust Income and Ownership; Statute of Limitations
By Tax Court, The-Tax-Court-in-Brief Insights
Feb 24, 2023
Tax Court in Brief | Avery v. Comm’r | Collection Due Process and a Lawyer’s Race Car Business Expense Deductions
By Tax Court, The-Tax-Court-in-Brief Insights
Feb 24, 2023
Unreported Foreign Accounts? How to Choose the “Right” International Tax Attorney to Help You
By Attorneys, Cross-Border Tax Insights, International Tax, OVDP, Streamlined Filing
Feb 23, 2023
Does a Treaty Govern FBAR Reporting Obligations: A Federal Court Answers “Yes”
By Cross-Border Tax Insights, FBAR, International Tax, Tax Treaty
Feb 21, 2023
Tax Court in Brief | Kemegue v. Comm’r | Additions to Tax for Failure to File
By Tax Court, The-Tax-Court-in-Brief Insights
Feb 17, 2023