The Tax Adviser

Revocable trusts and the grantor’s death: Planning and pitfalls

Planning with revocable trusts has become increasingly popular in recent years. In many instances, the motives for using a revocable trust are nontax and include avoiding probate, asset protection ...
The Tax Adviser

Taxpayers’ rights and the IRM: Part 1

This first part of a two–part series on taxpayer rights and Internal Revenue Manual (IRM) procedures addresses questions including whether an anticipated liability can be part of an installment ...
The Tax Adviser

Cap raised, strings attached: The 2025 SALT shake-up

The deductibility of state and local (SALT) taxes has been at the center of tax debates since the original $10,000 cap on the individual deduction was introduced by 2017’s Tax Cuts and Jobs Act (TCJA) ...
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

A walk through the step-transaction doctrine

The IRS may apply the step-transaction doctrine, a rule of substance over form, in a variety of taxpayer circumstances to deny tax benefits derived from a series of transactions that should more ...
The Tax Adviser

Personal Goodwill: Alive and Well Indeed!

Recent Tax Court decisions in Bross Trucking, Inc., T.C. Memo. 2014-107, and Estate of Adell, T.C. Memo. 2014-155, illustrate that with the right facts, the sale of personal goodwill, as an asset ...
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

Beware the personal holding company tax

Editor: Valrie Chambers, CPA, Ph.D. Congress reduced the highest rate of income tax on corporations from 35% to 21% in the law known as the Tax Cuts and Jobs Act, P.L. 115-97. At the same time, the ...
The Tax Adviser

R&D tax credits: A new era of disclosure and documentation

Editor: Jessica L. Jeane, J.D. While Harper ultimately prevailed, the case underscored a broader issue: Taxpayers cannot expect IRS audit action to validate claims that are procedurally weak at filing ...
The Tax Adviser

White House makes recommendations on digital asset transactions

Editor: Susan M. Grais, CPA, J.D., LL.M. The presidential report notes that “the IRS does not have authority to require digital asset exchanges to report on controlling persons of many shell companies ...
The Tax Adviser

Foreign financial asset filing requirements: Coming into compliance

On occasion, taxpayers holding investments in foreign financial assets or with foreign financial institutions may find themselves in the uncomfortable position of realizing that they have failed to ...
The Tax Adviser

Multistate corporate income taxes: An exercise in nexus and apportionment

The case requires students to assume the role of an entry–level tax professional in a public accounting firm. Students are given the task of calculating the state income tax liability for a ...