Ideas & Insights

Recently published IRS guidance provides insight into the Service’s expectations regarding transfer pricing documentation

Advisor must document amounts used to “investigate” an actual buy or sell – a study may make sense if amounts are substantial.

Fund management companies face difficult challenges in determining their state income tax filing obligations and apportionment rules.

Individuals and their advisors need to be familiar with the various IRA tips and traps to avoid negative consequences.

Transition rules for proposed built-in gain regulations helpful, but do they signal impending finalization of anti-taxpayer rules?

Notwithstanding unfavorable changes to the Code, capital gain treatment is still available on the sale of patents in certain scenarios.

The IRS has published final section 6050Y regulations requiring reporting of sales and acquisitions of certain life insurance contracts.

New guidance from the UK’s Her Majesty’s Revenue and Customs provides more clarity for businesses engaged digital asset businesses.

All companies seeking QI, WP, or WT status for 2019 must apply by Nov. 15, 2019 to have an agreement in effect.

Guidance would facilitate transitions of existing debt and derivatives to alternative benchmark rates without creating taxable exchanges.

Target company’s deduction claim denied because investment banking firm did not provide services to Target or for Target’s benefit.

New IRS cryptocurrency guidance provides much needed clarity but may require changes to returns not yet filed.

The IRS announced new relief procedures from paying back taxes for certain former citizens who wish to become compliant.

Fluctuation in value of stock did not impact exception to gain recognition, but no ruling on overall tax-free nature of reorganization.

The IRS has begun sending over 10,000 letters to certain taxpayers advising them to report virtual currency transactions.

A refund opportunity exists for taxpayers who paid the CSG and CRDS French social taxes thanks to new guidance from the IRS.

Treasury and the IRS finalize and withdraw certain provisions contained in previously issued temporary section 987 regulations.

U.S. companies with Mexican subsidiaries should re-examine whether they are at risk of audit, or of losing the use of their NOLs.

Proposed rules address many open issues and would prescribe complex calculations for taxpayers deducting business interest expense.

IRS Deputy Associate Chief Counsel Daniel McCall said government is working on regulations to correct downward attribution of CFC status.