A common cross-border reorganization can doom eligibility for the valuable gain exclusion without thoughtful planning.

Current developments in S corporations This annual update covers recent developments relating to S corporations, including IRS relief for common inadvertent S election lapses; the transfer of ...

While the IRS has discretion to provide relief, Sec. 7508A(d) provides a mandatory tax deadline postponement. In either case, the ‘lookback’ limitation period for refunds remains a concern.

Profits–interest partners frequently are allocated a share of the gain recognized in connection with a liquidity event. This allocation can lead to unexpected results related to Sec. 1245 recapture.

The taxation of Division I college sports may change once universities begin paying athletes directly, which will be permitted under a settlement of antitrust litigation against the NCAA and major ...

A Joint Committee on Taxation report’s language raises questions about the running of the statute of limitation for liability for the Sec. 965 transition tax.

The Eighth Circuit, affirming a district court, held that because a wife had no property interest in a home owned by her husband that was sold in a judicial sale to satisfy his federal tax debts, she ...

Intangible property transactions are a minority of those covered by advance pricing agreements, despite their generally high risk for taxpayers.

AICPA members providing tax representation or return preparation services need to comply with both the AICPA Statements on Standards for Tax Services and Treasury Circular 230.

Hospital facilities must meet the requirements of Sec. 501(r) provisions of the Patient Protection and Affordable Care Act, P.L. 111-148 to retain tax-exempt status.

Although the deadline for filing a challenge to an IRS employment status determination is nonjurisdictional, an employer’s facts did not warrant equitable tolling, the Tax Court held.

The Tax Adviser—the magazine of planning, trends, and techniques—reports and explains federal tax issues to tax practitioners.