The Tax Adviser

Estate of McKelvey highlights potential tax pitfalls of variable prepaid forward contracts

Andrew McKelvey was the founder and former CEO of Monster Worldwide Inc. As such, he held a large amount of Monster stock with zero basis. The amount of stock to be delivered was determined by a ...
The Tax Adviser

Planning with charitable remainder trusts

First, ordinary income and such undistributed income of the trust for prior years; Second, capital gain (including unrecaptured Sec. 1250 gain and gain on collectibles taxed at 28%) and such ...
The Tax Adviser

Preserving the limitation statute for ERC claims

Under normal IRS procedures, filing a written protest contesting a disallowance gets a case in front of an IRS Appeals officer for consideration. After all, the IRS has disallowed the claim at this ...
The Tax Adviser

The role of REITs for foreign investors in US real estate

Editor: Robert Venables, CPA, J.D., LL.M. Foreign persons investing in U.S. real estate face unique tax complexities under the Internal Revenue Code. Navigating these complexities is crucial to ...
The Tax Adviser

Current developments in S corporations

Sec. 1361 sets forth the basic qualifications for S corporation status. Among the most important are the limitation on types of shareholders and restrictions to a single class of stock. Tax Court ...
The Tax Adviser

Microcaptive insurance arrangements subject to new rules

This article examines the final regulations governing microcaptive insurance arrangements and their effect on taxpayers and their advisers. For background, this article also provides an overview of ...
The Tax Adviser

Global expansion of e-invoicing and digital reporting obligations for nonresidents

Editor: Mary Van Leuven, J.D., LL.M. Mary Van Leuven, J.D., LL.M., is a director, Washington National Tax, at KPMG LLP in Washington, D.C. For additional information ...
The Tax Adviser

CHIPS Act final regs. offer many taxpayer-friendly provisions

The final regulations 1 issued by Treasury and the IRS to implement the advanced manufacturing investment credit (AMIC) include many taxpayer–friendly provisions. Found in Sec. 48D, the AMIC benefits ...
The Tax Adviser

How S elections go wrong and how to fix them

To be an S corporation is to live dangerously. After all, in order to be taxed as an S corporation, the corporation 1 must file a complete and timely election with the IRS and meet and maintain strict ...
The Tax Adviser

Deferred revenue: Transactional triggering events

Operating businesses in various industries often receive advance payments for goods or services that will be provided in the future, and the presence of deferred or unearned revenue in a balance sheet ...
The Tax Adviser

ING trusts: How they work and their continued viability

In the context of trusts, CPAs may have heard someone mention WINGs, DINGs, or NINGs. This article aims to explain the advantages, requirements, and potential drawbacks of these trusts for estate ...
The Tax Adviser

Elections under the new Sec. 987 final regs.

For taxpayers that have a qualified business unit (QBU) with a functional currency other than the dollar, Sec. 987 provides rules on how to adjust for changes in exchange rates. On Dec. 10, 2024, ...