The Tax Adviser

Partnership and LLC Taxation

In a letter to Treasury and the IRS, the AICPA seeks changes to tax reporting requirements for partnerships and S corporations. In Soroban Capital Partners, the Tax Court analyzed the roles, ...
The Tax Adviser

How a CPA and wealth adviser partnership can guide families through transition

A It’s more prevalent and often emerges earlier than many realize. According to the U.S. Census Bureau, the average age of widowhood in the United States is approximately 59, an age when many couples ...
The Tax Adviser

Two Tax Court rulings expose overvalued conservation easements

In the cases, the Tax Court determined the value of a conservation easement donated to charity using the comparable sales method instead of the discounted-cash-flow method.
The Tax Adviser

The ongoing fight against frivolous tax arguments

Taxpayers who make frivolous arguments in Tax Court risk the imposition of penalties by the court of up to $25,000.
The Tax Adviser

November 2025 - The Tax Adviser

Final regulations provide comprehensive guidance for tax reporting of transactions involving these increasingly common assets, and the IRS has granted transition relief in key areas.
The Tax Adviser

Preparer’s intent to evade tax extends taxpayer’s limitation period

Stephanie Murrin underpaid her taxes from 1993 to 1999 because her tax preparer, Duane Howell, placed false or fraudulent entries on her tax returns with an intent to evade tax. Murrin did not intend ...
The Tax Adviser

Notice 2025-27 provides interim guidance on corporate AMT

The notice provides an optional interim simplified method of determining whether a corporation is an applicable corporation for purposes of the corporate AMT and relief from the Sec. 6655 penalty for ...
The Tax Adviser

Tax-advantaged ABLE accounts for disabled individuals

The Achieving a Better Life Experience (ABLE) Act of 2014 allows states to establish an ABLE program to assist persons with disabilities in building up tax – free (or in some cases tax – deferred) ...
The Tax Adviser

Transfer pricing: The C-suite needs to be informed

For the most part, the CEOs of large multinational corporations (MNCs) do not need to know much about tax issues. CEOs are already busy, charged with developing a vision and strategy for growth, ...
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

Stock option planning: Generating value

Annually, millions of Americans are granted stock options by their employer. The majority of recipients are high-net-worth individuals (or soon will be). The positive impact of this wealth-creation ...
The Tax Adviser

Revocable trusts and the grantor’s death: Planning and pitfalls

Planning with revocable trusts has become increasingly popular in recent years. In many instances, the motives for using a revocable trust are nontax and include avoiding probate, asset protection ...