The Tax Adviser8d
FTR notification requirement for taxpayers under LB&I examination
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 ...
The Tax Adviser8d
The research credit: Business-component requirement
The Fifth Circuit’s decision in Grigsby, 86 F.4th 602 (5th Cir. 2023), emphasizes the need for taxpayers to clearly define business components when preparing and documenting their Sec. 41 credit. It ...
The Tax Adviser8d
Current developments in taxation of individuals: Part 1
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 ...
The Tax Adviser8d
Sec. 280G and the evolving executive compensation landscape
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 ...
The Tax Adviser8d
The final countdown: Benefiting from the higher BEA before it potentially expires
Editors: Alexander J. Brosseau, CPA, and Greg A. Fairbanks, J.D., LL.M. Given this uncertainty, taxpayers expecting to have a taxable estate who have the wherewithal and desire to make gifts may ...
The Tax Adviser8d
A closer look at the costs of borrowing
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 ...
The Tax Adviser8d
IRS increases scrutiny of business aircraft use
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 Adviser8d
Beyond the forms: The tax return as a beacon for financial planning
One can argue that understanding a client’s marginal tax rate should be one of the foundations of effective investment management. After all, investors seek to optimize after–tax performance. Some ...
The Tax Adviser8d
Loper Bright and the future of deference to state tax authorities
Chevron deference has historically carried great weight in the tax world, given that many aspects of tax law are largely administrative law. At the state level, state tax agencies have amassed and ...
The Tax Adviser8d
Planning for the AMT
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 ...
The Tax Adviser8d
The complex simplicity of partnership interests exchanged for services
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 ...
The Tax Adviser8d
March 2025 - The Tax Adviser
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2024. The Fifth Circuit’s decision ...