For years, the California Franchise Tax Board (FTB) has taken the position that trusts are subject to California state income tax on all of their California-source income, and that ...

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 ...

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 ...

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 ...

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 ...

Only certain types of trusts are permitted to hold an interest in an S corporation. Two of these are an electing small business trust, or ESBT, and a qualified Subchapter S trust, or QSST. An ESBT is ...

As the world becomes more mobile, practitioners and fiduciaries must be familiar with international tax issues, including the complex withholding and reporting requirements that arise when U.S. trusts ...

Many practitioners who counsel business clients, both small and large, are familiar with the difficult challenges that quickly arise when taxes are withheld from employee wages but not turned over to ...

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 ...

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 ...

Under normal IRS procedures, filing a written protest contesting a disallowance gets a case in front of an IRS Appeals officer for consideration. After all, the IRS has disallowed the claim at this ...

A binding, nonjudicial settlement agreement, where available under state law, offers a practical alternative to a probate court ruling to revise a trust’s terms to comply with requirements to be a ...