The Tax Adviser

The new CFC tax landscape after OBBBA

H.R. 1, P.L. 119-21, known as the One Big Beautiful Bill Act (OBBBA), introduced significant changes to the controlled foreign corporation (CFC) rules that affect U.S. taxpayers with foreign corporate ...
The Tax Adviser

Condo casualty losses: Deductions for common-interest property

After a condominium or other common–interest property suffers a casualty loss, individual owners may receive a large assessment to cover the uninsured portions of the loss. Since those owners ...
The Tax Adviser

International Tax

Foreign entrepreneurs and others entering the United States, whether for short-term visits or permanently, should be mindful of the complex U.S. income tax and foreign information-reporting rules that ...
The Tax Adviser

Trust distributions: Timing, tax, and practical considerations

Distributions from a trust to a beneficiary can take many forms and can have widely varying consequences. The timing of the distribution, the type of asset distributed, the requirements under the ...
The Tax Adviser

Management fee waivers in investment funds: Tax treatment and regulatory considerations

Many investment funds employ an economic arrangement in which the general partner receives a carried interest, and the management company, which often shares common ownership with the general partner, ...
The Tax Adviser

Tax ethical standards in data protection and reliance on tools

To follow ethical behavior in the accounting profession, CPAs must observe the AICPA Code of Professional Conduct (the AICPA Code). CPAs who perform tax services must also follow the AICPA Statements ...
The Tax Adviser

Gray areas of Sec. 1202 warrant regulatory guidance

Editor: Mo Bell-Jacobs, J.D. Through Sec. 1202, Congress granted taxpayers a significant boon to encourage new investment in developing companies. The provision allows qualifying investors in certain ...
The Tax Adviser

A case study on ILITs: What went wrong, how to fix it, and best practices for prevention

Editor: Mo Bell-Jacobs, J.D. Irrevocable life insurance trusts (ILITs) continue to be a cornerstone of estate planning for many clients. Advisers often recommend ILITs to accomplish key objectives: ...
The Tax Adviser

Considerations for intergenerational split-dollar arrangements

Though the lifetime estate tax exemption remains historically high at $15 million, 1 advisers still encounter many households whose estates will face a large estate tax liability despite their best ...
The Tax Adviser

Estate planning in a post-OBBBA world

If an individual plans to utilize their BEA, the following strategies can be considered. Outright taxable gifts: For those not interested in employing trusts or other complicated gifting strategies, ...
The Tax Adviser

Dissolving business taxpayers: Selected procedural implications

All dissolving entities must file a final return with the IRS, which sounds simple, but taxpayers should remember that the due date of final returns is based on the date of dissolution (not the full ...
The Tax Adviser

Navigating the Form 1099-DA reporting maze

In 2021, Congress enacted the Infrastructure Investment and Jobs Act (IIJA), P.L. 117-58, which requires brokers to report digital asset transactions to the IRS and taxpayers. In enacting the IIJA, ...