Sec. 1361 sets forth the basic qualifications for S corporation status. Among the most important are the limitation on types of shareholders and restrictions to a single class of stock. Tax Court ...

Just as for other businesses, tax considerations come to the fore when CPA practices combine. This article delves into some of the possible entity deal structures for CPA firm mergers and acquisitions ...

The IRS and Treasury on Nov. 29, 2024, released proposed regulations (REG-105479-18) addressing previously taxed earnings and profits (PTEP) of foreign corporations. The proposed regulations provide ...

Amid new limitations, strategies remain for optimizing tax-efficient support for colleges and universities.

This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2024. Certain tax rules and ...

Adjustments under the disregarded-payment and foreign tax credit rules are often overlooked. This practical framework includes a step-by-step guide and example.

The Fifth Circuit, overruling the Tax Court, held that for purposes of the Sec. 1402(a)(13) exclusion from self-employment tax, “limited partner” means a partner in a limited partnership that has ...

The Tax Court advised a taxpayer that filing a second petition would not allow another IRS Collection Due Process review.

The IRS may apply the step-transaction doctrine, a rule of substance over form, in a variety of taxpayer circumstances to deny tax benefits derived from a series of transactions that should more ...

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 ...

First, ordinary income and such undistributed income of the trust for prior years; Second, capital gain (including unrecaptured Sec. 1250 gain and gain on collectibles taxed at 28%) and such ...

Only certain types of trusts are permitted to hold an interest in an S corporation. Two of these are an electing small business trust, or ESBT, and a qualified Subchapter S trust, or QSST. An ESBT is ...