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 ...

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 ...

Taxpayers generally must capitalize amounts paid to improve a unit of property. A unit of property is improved if the cost is made for (1) a betterment to the unit of property; (2) a restoration of ...

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 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 ...

On the surface, the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA), P.L. 96-499, seems straightforward enough: Foreign persons must pay a 10% or 15% tax when they sell a piece of U.S.

S corporation shareholders generally prefer dividend distributions of their S corporations’ profits over compensation payments from the S corporations because the compensation payments are subject to ...

With more assets held in trust and higher marginal tax rates, many clients and advisers are now considering distributions from trusts to beneficiaries as a way to shift the tax burden to individuals ...

Annually, millions of Americans are granted stock options by their employer. The majority of recipients are high-net-worth individuals (or soon will be). The positive impact of this wealth-creation ...

Many high-net-worth individual taxpayers are charitably inclined and endeavor to tax-optimize their philanthropic goals. The opportunity for charitable planning in today’s environment is immense and ...

Editor: Rochelle Hodes, J.D., LL.M. The ability to defer taxes on exchanges of like-kind property dates back to the Revenue Act of 1921, P.L. 67-98. Sec. 1031, the current statutory authority relating ...

An S corporation, unlike a C corporation, generally escapes income tax at the corporate level; instead, its items of income, deduction, credit, etc., flow through to its shareholders, who calculate ...