The plain language of Sec. 245A disallowed a dividends-received deduction for a controlled foreign corporation, the IRS ...

Form 7217, Partner’s Report of Property Distributed by a Partnership, debuted for 2024, intended to apprise the IRS of factors in a partner’s basis computation.

Investors holding less than 10% of a controlled foreign corporation (CFC) are generally no longer shielded from double taxation under both the passive foreign investment company and CFC rules.

The AICPA said Treasury is "headed in the right direction" by suspending enforcement of beneficial ownership information (BOI) reporting requirements and urged it to extend reporting deadlines to at ...

A recent Chief Counsel Advice memo determined that the deductions were disallowed as fines or penalties under Sec. 162(f).

Editor: Greg A. Fairbanks, J.D., LL.M. In response to federal changes to net operating losses (NOLs) and fluctuating fiscal conditions, several states have recently enacted noteworthy legislation that ...

For the most part, the CEOs of large multinational corporations (MNCs) do not need to know much about tax issues. CEOs are already busy, charged with developing a vision and strategy for growth, ...

Regardless of whether a limited liability company (LLC) has a Sec. 754 election in effect, a partnership-level tax basis adjustment is required when an LLC interest is transferred (including a ...

Between November 2001 and September 2005, Raju Mukhi created three foreign entities, including Sukhmani Partners II Ltd., a foreign corporation for U.S. tax purposes. From 2002 through 2013, Mukhi did ...