Using IRS Form 843 for Abatements
The IRS regularly tacks on penalties wherever they can. Did [...]
Debt Cancellation Tax Consequences
Financially distressed borrowers may have some or all of their [...]
Partnership Special Allocations
One of the advantages of operating a business as a [...]
Change In Ownership Exclusions
Change of ownership exclusions. Change of ownership does not include: [...]
Expatriates
Expatriates & SourcingExpatriatesThe tax code provides an exemption for expatriates [...]
Controlled Foreign Corporations (CFCs)
Controlled Foreign Corporations Now we are going to switch focus [...]
Transfer Pricing and Transfer of Property Outside the US
Transfer Pricing and Transfer of Property Outside the US Transfer [...]
Corporations and Branches
I will elaborate on the following areas: Difference between a [...]
Bankruptcy Discharge of Taxes-Introduction
Contrary to what you may believe or have heard, most [...]
Like Kind Exchanges of Real Property
Like Kind Exchanges of Real Property