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Introduction of Issues to Be Addressed The Tax Cuts and Jobs Act of 2017 (TCJA 2017) created a new opportunity for both deferral and possible exclusion of gains for investments [...]

The Internal Revenue Code places substantial restrictions on the ability to recognize a loss or deduction resulting from a transaction with a related party. From limits on the deduction of [...]

On January 16, 1996, Tax Executives Institute submitted the following comments to the Internal Revenue Service, concerning the proposed revision Of Revenue Procedure 65-17, which addresses the collateral consequences of [...]

Borrowing from a family member or having a relative guarantee a loan can be vital to the economic well-being of certain individuals. Unfortunately, these loans often are granted in less [...]

Overview This article considers whether, in the Canada-U.S. context, an efficient transfer pricing strategy can be developed under Canadian law and, if so, how. This gives rise at least to [...]

Overview The IRS recently issued proposed anti-conduit regulations under Sec. 7701(l) designed to prevent both abuse of the portfolio interest exemption and treaty shopping by disregarding the existence of a [...]

On Apr. 8, 1994, the IRS issued proposed regulations(1) under Sec. 1502 that revise the intercompany transaction system of the consolidated return regulations. The goal is to ensure, when practical [...]

On Apr. 8, 1994, the IRS issued anxiously awaited proposed regulations(1) under Sec. 1502 that revise the intercompany transaction system of the consolidated return regulations. The goal is to ensure, [...]

On December 7, 1993, representatives of Tax Executives Institute met with officials of Canada's De Revenue (Revenue Canada) to discuss pending income tax issues. (A separate meeting was held on [...]

On June 17, 1994, Tax Executives Institute submitted the following comments to the Internal Revenu regulations under section 7701(l) of the Internal Revenue Code. The Institute's comments on the so-c [...]

Editor's Note: In this article, Lawrence M. Axelrod analyzes the Department of the Treasury and In Service's proposed consolidated return regulations relating to intercompany transactions. Because of complexity of the [...]

On June 8, 1994, Tax Executives Institute filed the following comments on proposed regulations und of the Internal Revenue Code, relating to the computation of combined taxable income under the [...]

On December 8, 1993, Tax Executives Institute held its annual liaison meeting with officials of the Canadian Department of Finance on Excise and Goods and Services Tax issues. In connection [...]

Consolidated groups must apply the new intercompany transaction rules for tax years beginning after July 11, 1995. Generally, Regs. Sec. 1.1502-13 provides a single-entity approach in determining the tax consequences [...]

Taxpayers who control more than one S corporation should be aware of the Service's position on back-to-back loans. S shareholders are allowed to deduct losses to the extent of their [...]

On June 14, 1994, the IRS issued the revised Internal Revenue Manual relating to transfer pricing audits for years beginning after Apr. 21, 1993. The revisions expand this manual from [...]

S shareholders who restructure their holdings to benefit from opportunities created by the Small Business Job Protection Act of 1996 (SBJPA) should be alerted to provisions in final regulations issued [...]

The name DHL is as synonymous with international courier service as FedEx is with the domestic courier business. A recent Tax Court decision centered on a related-party sale of the [...]

As a general rule, taxpayers cannot deduct losses on transactions between related parties. IRC section 267(f) provides a special rule for losses between "commonly controlled" corporations. The loss is deferred [...]

This item is an update of the May 1997 Tax Clinic item (Vol. 28, No. 5, p. 276) that raised several questions on application of the related-party like-kind exchange provisions [...]

Sec. 1031 provides for deferral of gain or loss realized on an exchange of property when the taxpayer acquires property of a like kind. Sec. 1031(f) provides special rules when [...]

On October 11, 1994, the IRS issued the first part of proposed regulations on conduit financing arrangements under IRC section 7701(l). The proposed regulations provide rules under which an IRS [...]

Recently, an IRS official informally stated that thought has been given to reconsidering the Service's position on Rev. Ruls. 91-5 and 92-86 (both dealing with Sec. 304 cross-chain transfers) and [...]

Sec. 163(j), enacted by the Revenue Reconciliation Act of 1989, placed substantial restrictions on the amount of certain related-party interest expense deductions a foreign-owned U.S. corporation may take in computing [...]

Temporary regulations under Sec. 6662 (as updated by the Revenue Reconciliation Act of 1993) have been issued by the IRS to replace the 1993 proposed regulations and provide guidance for [...]

Kenco Restaurants, Inc., TC Memo 1998-342, involved members of a commonly owned group of 14 corporations (the group). Except for BKK Management, Inc. (BKK), each group member either owned and [...]

Final transfer pricing regulations under Internal Revenue Code Section 482 maximize the extent of relevant information taken into account in allocating prices between parent companies and their foreign subsidiaries. They [...]

Facts Bill owns a vacation home in an area in which his son-in-law, Carl, practices medicine. Carl incorporated his medical practice several years ago, and owns all of the corporation's [...]

Facts Martina, Ivan, Boris and Chrissy, who are brothers and sisters, and Jimmy Hana, Steff and Mats, their respective spouses, own equal 12.5% interests in Land Racket, a partnership that [...]