The Tax Adviser

Income taxation of trusts in California

For years, the California Franchise Tax Board (FTB) has taken the position that trusts are subject to California state income tax on all of their California-source income, and that ...
The Tax Adviser

IRS Practice & Procedure

In a letter to Treasury and the IRS, the AICPA seeks changes to tax reporting requirements for partnerships and S corporations. The IRS released initial details on Trump accounts, a new type of IRA ...
The Tax Adviser

S Corporation Income Taxation

In a letter to Treasury and the IRS, the AICPA seeks changes to tax reporting requirements for partnerships and S corporations. The IRS may grant a reasonable extension if the taxpayer provides ...
The Tax Adviser

Partnership and LLC Taxation

In a letter to Treasury and the IRS, the AICPA seeks changes to tax reporting requirements for partnerships and S corporations. In Soroban Capital Partners, the Tax Court analyzed the roles, ...
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

Employment tax penalties: Let’s keep it civil

Many practitioners who counsel business clients, both small and large, are familiar with the difficult challenges that quickly arise when taxes are withheld from employee wages but not turned over to ...
The Tax Adviser

The kiddie tax and unearned income from scholarships

Every fall, students all over the country set off to attend various colleges and universities. With the rising cost of higher education, many of these students are looking forward to receiving some ...
The Tax Adviser

Private equity and F reorganizations involving S corporations

Prior to the COVID-19 pandemic, the merger-and-acquisition (M&A) market had a string of years of strong activity. Seemingly overnight, COVID-19 changed the M&A landscape, as many transactions were put ...
The Tax Adviser

Taxation of undocumented immigrants

Undocumented immigrants venture to the United States from all parts of the world and endure enormous challenges in their new life, ranging from cultural ones to those that are language–oriented in ...
The Tax Adviser

Deducting startup and expansion costs

A corporation can deduct up to $5,000 of business startup costs under Sec. 195. The $5,000 deduction is reduced dollar for dollar (but not below zero) by the cumulative amount of startup costs ...
The Tax Adviser

Guide to expensing HVAC costs

Each year, tax professionals who deal with real estate must evaluate the most recent building expenditures and determine which items should be deducted as a repair expense or capitalized. Of all the ...
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 ...