A common cross-border reorganization can doom eligibility for the valuable gain exclusion without thoughtful planning.

The Tax Adviser—the magazine of planning, trends, and techniques—reports and explains federal tax issues to tax practitioners.

EXECUTIVE SUMMARY The Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 clarified the rights of debtors and creditors to retirement assets in federal bankruptcy proceedings, but state ...

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.

This article summarizes the options available to taxpayers to come into compliance with FBAR and information reporting obligations.

This article focuses on the potential criminal consequences that can arise when a business fails to collect or pay over withheld tax.

This article explains the procedures and tax compliance issues that fiduciaries face before domestic trust or estate distributions are paid or allocated to foreign beneficiaries.

The impact of community property laws on tax issues is vast and complex. Advisers must be mindful of this when learning about their clients, whose geographical history may be as important to consider ...

By knowing the factors courts consider in determining whether a taxpayer meets the requirements for the reasonable-cause exception, and how the courts have applied the factors, tax advisers can help ...

Once the exclusive province of large accounting and law firms, now even the smallest firms must master cross-border tax issues.

Whether contributions, earnings, and distributions are includible in the taxpayer’s income depends on the type of foreign pension plan and whether a tax treaty exempts an event that is otherwise ...

In the typical Crummey trust, a periodic contribution of assets to the trust is accompanied by an immediate withdrawal power that gives the beneficiary the right to withdraw the contribution for a ...