The proposed merger of the Office of Professional Responsibility and the Return Preparer Office would blur “the public’s ability to perceive the distinction between credentialed, uncredentialed, and ...
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 ...
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 ...
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 ...
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 ...
In a world that is now a “global village,” even small firms must master cross-border tax issues to serve their clients well. There are two basic types of cross-border transactions. Outbound ...
Editor: Mary Van Leuven, J.D., LL.M. One of the Internal Revenue Code’s oldest provisions may prove useful in managing a taxpayer’s position under some of its newest provisions. In considering how ...
The basic rule for when a partner recognizes gain as a result of a distribution is found in Sec. 731(a)(1), which applies to both current distributions (from current income and activities) and ...
The federal income taxation of gains (and losses) from the disposition of investments in collectible assets (collectibles) is relatively unfamiliar to many practitioners for several reasons. First, ...
Editor: Kevin D. Anderson, CPA, J.D. After Treasury finalized regulations under Sec. 336(e) in May 2013, it became possible for a qualified stock disposition (QSD) of S corporation stock to be treated ...
The Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 clarified the rights of debtors and creditors to retirement assets in federal bankruptcy proceedings, but state attachment and ...
A binding, nonjudicial settlement agreement, where available under state law, offers a practical alternative to a probate court ruling to revise a trust’s terms to comply with requirements to be a ...