The Tax Adviser

Intangible property contributions to an LLC

Contributions of intangible property to an LLC classified as a partnership are generally eligible for nonrecognition ...
The Tax Adviser

AI risks to the Sec. 7525 practitioner privilege

Practitioners’ workpapers and communications with taxpayers are often protected from compelled disclosure, but when they use ...
The Tax Adviser

Structuring an LLC under a target capital account framework

With their insight into tax effects of allocations, accountants should be integral players in devising limited liability ...
The Tax Adviser

No deduction for attorneys’ fees from Fair Credit Reporting Act suit

The taxpayers’ suit did not involve claims of unlawful discrimination, as required for a deduction under Sec. 62(a)(20), and ...
The Tax Adviser

OID in modern corporate debt: Timing, yield, and reporting considerations

Reporting income and claiming deductions from original issue discount can be overlooked in today’s variety of types of loans, ...
The Tax Adviser

ASU 2023-09: Public company takeaways and 2026 private company adoption

With the first wave of public company filings now available, early implementation trends are emerging, providing useful ...
The Tax Adviser

Beauty may be in the eye of the beholder, but is value?

Adhering to the valuation and substantiation rules for charitable donations of noncash property can avoid IRS challenges.
The Tax Adviser

Taxpayers’ rights and the IRM: Part 2

Acquaintance with relevant Internal Revenue Manual provisions can aid practitioners in protecting clients’ rights in tax ...
The Tax Adviser

Gift or hold? Basis step-up and transfer tax planning after H.R. 1

With a higher basic exclusion amount now permanent, rather than transferring assets during life, taxpayers and their heirs ...
The Tax Adviser

Permanent establishment risk from remote work and the OECD’s new guidance

Employees working remotely in a foreign country can give their employer a taxable presence there. An update from the ...
The Tax Adviser

Practical considerations for deducting abandoned M&A transaction costs

Transaction costs from an abandoned merger and acquisition may be treated as capitalizable to facilitate a second transaction ...
The Tax Adviser

Estate Tax

With a higher basic exclusion amount now permanent, rather than transferring assets during life, taxpayers and their heirs may benefit by retaining them until death for a stepped-up basis. Care must ...