The One Big Beautiful Bill Act reshapes core elements of international taxation, including the rules for controlled foreign corporations, foreign-derived income and base erosion taxes.
An IRS attorney can move forward with a claim that the agency unlawfully discriminated against her when she didn’t receive an assistant manager branch manager position for which she applied. Kara ...
The IRS was not entitled to a presumption of proper mailing for a notice with an erroneous address that it contended the taxpayer nonetheless received timely, the Tax Court held.
IRS rules research and development services U.S. entities provide to their foreign parent principal company may be characterized entirely as foreign-derived deduction eligible income purposes.
The IRS has published a private letter ruling on Section 2056(b)(7), granting the taxpayer an extension of time to make a qualified terminable interest property (QTIP) election on a supplemental Form ...
In the aftermath of the Supreme Court’s 2024 landmark decision in SEC v. Jarkesy, courts across the country are grappling with a high-stakes constitutional question: can federal agencies unilaterally ...
The federal estate tax exemption increased again for 2025. Although the higher, IRS-inflation-adjusted number, announced last fall, may not have come as a surprise to most. However, 2025 is a pivotal ...
A common example is a jointly held rental property. A couple might want to split the income in a more tax-efficient way by altering ownership shares through a deed and then submitting a Form 17 ...
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