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A transfer of property may be treated as a Section 351 transaction even if it is followed by subsequent transfers of the property as part of a prearranged, integrated plan.

The IRS has issued a general legal advice memorandum, rejecting a taxpayer’s attempt to treat revenue attributable to a downloadable computer software application that allowed access to the taxpayer’s online banking system as qualifying domestic production gross receipts.

The IRS Office of Associate Chief Counsel (International) provided advice on the application of the Section 956 anti-abuse rule to a U.S. parent corporation.

These regulations are proposed to apply on the date of publication of the Treasury Decision adopting these rules as final regulations in the Federal Register.

One of the safe harbors for determining whether expenditures are repairs or improvements is similar to the safe harbor issued for wireline telecommunications networks in Rev. Proc. 2011-27.

The IRS has ruled in Rev. Rul. 2012-14 that, for purposes of measuring a partner’s insolvency, each partner treats a discharged nonrecourse debt of the partnership as a liability based on the allocation of income from discharge of indebtedness (COD income).

In a private letter ruling (PLR 201451009) released in December 2014, the IRS ruled two professional corporations owned by an individual could join a consolidated group of corporations.

The IRS ruled on April 25 (PLR 201230008) that certain warrants issued by a corporation were treated as stock.

On Aug. 9, 2013, the Internal Revenue Service published a notice in the Federal Register seeking comments on the recordkeeping burden placed on public charities and social welfare organizations (as well as qualified nonprofit health insurance issuers) subject to the excess benefit transaction rules.

The IRS has issued Notice 2026-40 addressing how qualified opportunity zones will transition under the One, Big, Beautiful Bill Act's new designation system.

On August 6, 2026, the IRS released Fact Sheet 2026-13, an expanded set of FAQs on the qualified overtime compensation deduction created by the One, Big Beautiful Bill Act. The update replaces January’s FS-2026-01 and marks the shift from 2025’s transition relief to the full compliance framework now in effect.

House Ways and Means Chair Paul Ryan, R-Wis., said he will begin negotiating a compromise on the extenders after returning from the August recess in September.

Early decisions about a start-up's legal structure can dramatically affect tax outcomes and financial returns as the company grows and reaches liquidity events. Understanding the Qualified Small Business Stock (QSBS) exemption and implementing proper structuring from the outset can significantly enhance returns for both founders and investors.

The change is effective for any refund claim that has not yet been reported by the IRS to JCT as of the date the bill is signed into law.

The recent Tennessee Court of Appeals ruling in Valenti Mid-South v. Farr is an significant reminder of how important careful franchise and excise tax planning can be for those engaged in real estate ventures in Tennessee.

IRS will require disclosure of uncertain positions on tax returns of businesses with more than $10 million in assets

A taxpayer generally realizes gain or loss from the sale or other disposition of property.