Ideas & Insights

The international tax landscape is shifting based on recent reports from the White House, Senate Finance Committee and U.S. Treasury.

Increasing capital gains rates and low corporate tax rates create opportunity for an exclusion of gain on Qualified Small Business Stock.

From retroactivity to loss of planning techniques, this year we face a unique set of concerns when considering gift and estate planning.

Bill would treat carried interest as ordinary income and subject to it to self-employment tax, regardless of the holding period.

Sweeping changes are coming. Don’t let required capitalization of research expenditures wreak havoc on your tax return.

Privately held C corporations may be able to maximize gain exclusions and unlock a lower corporate tax rate through section 1202.

Mexico released tax changes for 2021. Some new rules may have significant impact on U.S. companies doing business in Mexico.

Partially finalized regulations on business interest expense deductions provide helpful clarifications for multinational businesses.

Taxpayers should familiarize with Biden’s plan, remain vigilant for developments and position themselves to act at the appropriate times.

IRS modifies guidance on wages that are includible when computing section 199A deduction for taxpayers with short tax years.

Final regulations on the section 199A deduction and the DPAD for certain specified co-ops closely mirror guidance in proposed regulations.

Final regulations address self-charged interest and trading partnerships, but reserve on tiered partnerships and other items.

Final carried interest regulations ease rules for capital interest allocations as well as related party transfers.

New final regulations include rules for CFCs, depreciation/amortization ‘add-back recapture’ and self-charged interest.

The regulations largely mirror the proposed regulations with additional, mostly favorable, clarifications for taxpayers.

Learn why the IRS is increasing its scrutiny on high net worth athletes and entertainers, and what can be done before an audit.

The final regulations broaden the definition of real property compared to the more restrictive definition in the proposed regulations.

The IRS will release proposed regulations confirming the SALT deduction limit will not apply to entity-level taxes imposed on pass-throughs.

For corporations with NOLs that anticipate 2021 income, a change of fiscal year may mitigate the impact of the 80% NOL deduction limitation.

The CARES Act enacted a temporary suspension of the TCJA’s 80% limitation on the use of NOLs, this will impact FTC and ODL calculations.