After a cross-border merger or acquisition, related affiliates often integrate and use the acquired intangibles, such as new ...
Jorge Olavarrieta. vice president and general manager, ProTax Group, Intuit, discusses how leading tax firms actually make advisory work. AICPA members in tax practice assess how their return ...
Even though recent changes substantially reduced abuse concerns, U.S. corporate shareholders must still comply with the extraordinary reduction rules when deducting certain foreign dividends.
Focusing on private-equity acquisitions, this article compares merger forms and highlights tax considerations, particularly ...
Acquaintance with relevant Internal Revenue Manual provisions can aid practitioners in protecting clients’ rights in tax ...
Thresholds and ceilings for individual and corporate deductions under the law known as the One Big Beautiful Bill Act may ...
Hyatt appealed the Tax Court’s decision to the Seventh Circuit. On appeal, Hyatt renewed its arguments that the payments into ...
Practitioners must observe and protect time limits for requesting a refund, administrative appeals, and litigation.
Tax Court disallows part of a taxpayer’s Sec. 245A dividends-received deduction and holds post–Sec. 965(c) amount must be ...
Taxpayers issuing related-party loans should assess the consequences if those debt instruments are determined to have a zero ...
Foreign companies can realize benefits from establishing domicile in the United States if they observe structural and special ...
Undocumented immigrants venture to the United States from all parts of the world and endure enormous challenges in their new life, ranging from cultural ones to those that are language–oriented in ...
Results that may be inaccessible to you are currently showing.
Hide inaccessible results