The Tax Adviser

VAT challenges in AI product development

Artificial intelligence may incrementally become a product’s component until it crosses a threshold into being a digital ...
The Tax Adviser

Taxation of Estates & Trusts

Proposed regulations issued Monday would raise the cost of the letter to $76, from the $56 set in 2025. High‑net‑worth families can preserve wealth across generations by pairing intentionally ...
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

Recent developments in estate planning

This annual update summarizes key changes advisers need to be aware of to ensure their clients’ estate plans remain effective and in line with their intentions. It covers developments in the estate ...
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

Planning for the AMT

Individuals are subject to two income tax systems: the regular income tax and the alternative minimum tax (AMT). Taxpayers must compute their tax under each system and pay the greater of the two ...
The Tax Adviser

A walk through the step-transaction doctrine

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 ...
The Tax Adviser

Microcaptive insurance arrangements subject to new rules

This article examines the final regulations governing microcaptive insurance arrangements and their effect on taxpayers and their advisers. For background, this article also provides an overview of ...
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

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

Gray areas of Sec. 1202 warrant regulatory guidance

Editor: Mo Bell-Jacobs, J.D. Through Sec. 1202, Congress granted taxpayers a significant boon to encourage new investment in developing companies. The provision allows qualifying investors in certain ...