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 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 ...

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 ...

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 ...

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 ...

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 ...

The Fifth Circuit’s decision in Grigsby, 86 F.4th 602 (5th Cir. 2023), emphasizes the need for taxpayers to clearly define business components when preparing and documenting their Sec. 41 credit. It ...

An often-cited belief is that 50% of marriages now end in divorce. Regardless of whether this statistic is accurate (for first marriages, the divorce rate more likely peaked at around 40% in the ...

Editor: Rochelle Hodes, J.D., LL.M. Expatriation is a major life decision with big tax implications for anybody thinking about giving up their U.S. citizenship or long-term permanent resident status.

One of the most substantial tax breaks for noncorporate taxpayers today is the federal income tax exclusion available upon the sale of qualified small business stock (QSBS). A sought-after tax break ...