What to Watch for in the Wake of the Tax Division’s Demise
The plan for restructuring DOJ’s Tax Division may further degrade tax compliance.
Tax Management Memo
Latest Tax Journals
Supreme Court Decision Modifies ERISA Litigation Landscape
The alternative safeguards identified in the Supreme Court’s Cunningham v. Cornell decision are discussed for avoiding costly time-intensive discovery for ultimately meritless ERISA claims.
Do Tax Rules Still Favor Charity Over Social Welfare Donations?
OBBBA reduces the income tax benefit of claiming a charitable deduction, prompting donors to reconsider tax implications when deciding between making a nondeductible contribution to a social welfare “lobbying” organization or a deductible contribution to a “charity” organization.
New Notices Make CAMT Regime More Favorable But More Complex
The IRS issued new guidance that would appear to lessen CAMT burdens for many large corporations, but the book-based tax regime remains exceedingly complex.
PLRs Reveal Pointers for Fixing Inadvertent §2632 Elections
Postseason baseball is a metaphor for practitioners seeking relief for a late allocation or election under §2642(g)(1).
SECURE 2.0 Act Reshapes Puerto Rico Retirement Savings Rules
In light of recent Puerto Rico and IRS guidance, some practical considerations on how the SECURE 2.0 Act changes to the Puerto Rico qualified retirement plan rules are analyzed.
Six Key Tax Considerations that Will Make or Break a Startup
An Alpine Mar practitioner discusses six key tax considerations for startups to be financially successful.
Employee Retention Credit Rules Are Still Progressively Evolving
Although the Employee Retention Credit expired over three years ago, claims are still being adjudicated, and taxpayers should strategize on how to expeditiously get refunds or handle disallowed claims, says a KPMG practitioner.
OBBBA Changes How High-Net-Worth Clients Use Life Insurance
The GOP tax and spending package increased the federal estate tax exemption, and high-net-worth individuals now have important choices to make as to what to do with their life insurance policies, says Henry Montag of The TOLI Center East.
New R&E Expensing Procedures Are Complex With Favorable Options
KPMG practitioners summarize the options available under Rev. Proc. 2025-28 for transitioning from TCJA to OBBBA treatment of R&E costs that offer flexibility for taxpayers, especially those who act before specified deadlines in 2025.
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