What do you do when the proverbial “tax man” is coming to collect on tens of billions of deferred gains? As part of the 2017 Tax Cuts and Jobs Act, 1 Congress established the qualified opportunity ...

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The Inflation Reduction Act extended and revised the Sec. 30D new clean vehicle credit and created a tax credit opportunity for used vehicles as well under Sec. 25E. For both credits, eligibility ...

Editors: Alexander J. Brosseau, CPA, and Greg A. Fairbanks, J.D., LL.M. Sec. 280G was enacted to address the potential for “golden parachutes” paid in connection with a corporate transaction that ...

Editors: Alexander J. Brosseau, CPA, and Greg A. Fairbanks, J.D., LL.M. Generally, taxpayers with a foreign tax redetermination (FTR) must file amended returns to notify the IRS of changes to their ...

Editors: Alexander J. Brosseau, CPA, and Greg A. Fairbanks, J.D., LL.M. The rise of benchmark interest rates (e.g., the Secured Overnight Financing Rate, SOFR) in recent years has led to higher ...

Editors: Alexander J. Brosseau, CPA, and Greg A. Fairbanks, J.D., LL.M. The taxation of the grant of a partnership interest exchanged for services is not a new topic. Partnership interests have been ...

Individuals are subject to two income tax systems: the regular income tax and the alternative minimum tax (AMT). Taxpayers must compute their tax under each system and pay the greater of the two ...

In February 2024, the IRS announced it would be significantly increasing scrutiny of the use of noncommercial business aircraft by corporations, partnerships, and high–income taxpayers (e.g., business ...

The Tax Court held that Sec. 6511(b)(2) and Sec. 6512(b)(3) are not subject to equitable tolling, so a taxpayer was not entitled to refunds of overpayments of income tax for his 2014 and 2015 tax ...