IRS Rules Stock Contributions Will Not Result in Deemed Dividends or Application of Gift Tax

A dominant or controlling shareholder may, for valid business reasons (e.g., to improve the...

Circuit Court Overturns Farhy Decision, Holds IRS Has Authority to Assess Section 6038 Penalties

The United States Court of Appeals for the District of Columbia Circuit on May 3 reversed the U.S....

Tax Court Holds Fund Engaged in U.S. Business via Investment Manager, Owes Withholding Tax

The Tax Court in a November 15 decision held that an investment fund partnership was engaged in a...

SECURE 2.0: Which provisions went into effect in 2024?

The Setting Every Community Up for Retirement Enhancement (SECURE) 2.0 Act was signed into law in...

IRS Form W-9 Revision Adds New Reporting Line on Foreign Partners and Beneficiaries

The IRS in March released a final 2024 revision of Form W-9, “Request for Taxpayer Identification...

Revisiting Eligibility for Small Business Taxpayer Exemptions

“An exemption from UNICAP? And no limitation on the amount of business interest expense I can...

Treasury, White House Release FY 2025 Budget and Green Book Detailing Administration’s Tax Proposals

The White House on March 11 released President Biden’s fiscal year 2025 budget proposal, followed...

IRS Releases Revised Procedural Guidance for Section 174 R&E Costs

On December 22, 2023, the IRS released Rev. Proc. 2024-09 containing new and revised procedural...

Notice 2024-10 Provides Corporate AMT Guidance on CFC Dividends and Applicable Financial Statements

The Inflation Reduction Act (IRA) enacted on August 16, 2022, created a new corporate alternative...

Tennessee Legislature Passes Franchise Tax Reform

On April 25, the Tennessee General Assembly passed a landmark reform (S.B. 2103) of the state's...