- How to scrutinize the IRS's position and arguments when guidance is not supported by the Internal Revenue Code, Treasury regulations, or another legal basis?
- A broader scope of work may qualify for purposes of the 100-hour significant participation activity test.
- For international investors, the classification of an LLC under US tax law can pose significant issues in relation to home-country tax laws.
- Action 7 of the BEPS project centers on changes to the definition of permanent establishment that may result in unintended adverse tax consequences for profit sharing arrangements.
- Complex rules and compliance issues may overshadow the wealth preservation nature of individual retirement accounts (IRAs) and qualified retirement plans.
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