News
Stacking" charitable contributions up to the 60% limit
5+ hour, 6+ min ago (20+ words) The OBBBA sought to clarify AGI'based charitable contribution deduction limits but instead added uncertainty over how those limits apply....
The end of deferral: Calculating QOZ gain recognition on Dec. 31, 2026
5+ hour, 6+ min ago (22+ words) A critical milestone in the qualified opportunity zone program looms, and understanding how to calculate the required deferred gain recognition is essential....
The historical shift in transfer pricing penalty enforcement
5+ hour, 6+ min ago (25+ words) Once rarely imposed, transfer pricing penalties are now a routine feature of IRS examinations, making the quality of transfer pricing documentation more important than ever....
Fuel tax expirations and new refund provisions require IRS guidance and improved administration
5+ hour, 6+ min ago (58+ words) With major fuel tax provisions expiring, the upcoming change to electronic payments, refunds for federal excise taxes, and the IRS excise tax hotline remaining unstaffed, taxpayers are facing a period of unusual uncertainty for federal excise taxes....
R&D credits and the computer rental rules time forgot
5+ hour, 6+ min ago (27+ words) Although computing has transformed radically in the past 45 years, the computer rental rules of Sec. 41 and regulations continue to reflect technology as it existed 1980s....
Trust distributions: Timing, tax, and practical considerations
1+ mon, 5+ hour ago (953+ words) This article explains the basics of trust distributions, focusing on key concepts, relevant rules and elections, and planning choices that can help trustees manage taxes for both the trust and its beneficiaries....
Sec. 163(j) after OBBBA: Leveraging cost-recovery accounting methods
1+ mon, 5+ hour ago (32+ words) A variety of capitalization strategies can increase deductible interest expense now that depreciation, amortization, and depletion are again added back to adjusted taxable income in calculating the Sec. 163(j) interest limitation....
Startups and the OBBBA: Rethinking C corporation vs. passthrough
1+ mon, 5+ hour ago (20+ words) With enhanced Sec. 1202 gain exclusion, permanency of Sec. 199 A, and other provisions, the calculus for entity choice has shifted....
Practical Sec. 174 A tax planning in the post-OBBBA landscape
1+ mon, 5+ hour ago (21+ words) Before adopting the newly reinstated expensing of research and experimental expenditures, taxpayers should first consider the strategy's broader tax effects....
Multigenerational wealth transfer with IDGTs and GST tax planning
1+ mon, 5+ hour ago (43+ words) High'net'worth families can preserve wealth across generations by pairing intentionally defective grantor trusts with thoughtful generation-skipping trust exemption planning....