The Tax Adviser

Adequate disclosure on gift tax returns: A requirement for more than gifts

Taxpayers may be subject to the risk that an IRS examination could increase (or create) a gift tax or estate tax liability many years after a gift is made. Practitioners can help clients limit this ...
The Tax Adviser

Foreign pension plans and the US-UK tax treaty

Editor: Kevin D. Anderson, CPA, J.D. In an increasingly global economy, workers are experiencing unprecedented mobility. As such, Americans living abroad, even for a limited time, often participate in ...
The Tax Adviser

Digital asset transactions: Broker reporting, amount realized, and basis

In December 2022, Treasury and the IRS stated that they intended to implement the Infrastructure Act amendments to the Code by issuing new regulations and providing forms and instructions for broker ...
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

Partnership distributions: Rules and exceptions

The basic rule for when a partner recognizes gain as a result of a distribution is found in Sec. 731(a)(1), which applies to both current distributions (from current income and activities) and ...
The Tax Adviser

Loans between members and LLCs

An advance of money by a member to a limited liability company (LLC) classified as a partnership may be in the form of a capital contribution or a loan. This distinction has significant tax ...
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 ...
The Tax Adviser

Avoiding an accuracy-related penalty through the reasonable-cause exception

Whether a taxpayer is subject to an accuracy-related penalty due to an understatement of tax is the most-litigated tax issue in recent years. Although the IRS wins a large majority of cases on this ...
The Tax Adviser

Planning with charitable remainder trusts

First, ordinary income and such undistributed income of the trust for prior years; Second, capital gain (including unrecaptured Sec. 1250 gain and gain on collectibles taxed at 28%) and such ...
The Tax Adviser

Smart tax strategies for lottery winners

Lottery fever remains at a high level lately, thanks in part to jackpots that sometimes exceed $1 billion, including the $1.334 billion Mega Millions winning ticket sold in July to individuals in ...
The Tax Adviser

Global expansion of e-invoicing and digital reporting obligations for nonresidents

Editor: Mary Van Leuven, J.D., LL.M. Mary Van Leuven, J.D., LL.M., is a director, Washington National Tax, at KPMG LLP in Washington, D.C. For additional information ...
The Tax Adviser

Electing S status by an LLC

An existing entity (such as a limited liability company (LLC) classified as a partnership) can elect under the check-the-box rules to be classified as a corporation. If the election is made, the ...