The IRC states that if there is a constructive sale of any appreciated financial position, such position is subsequently disposed of, and at the time of the disposition, the transaction resulting in ...

If there is a constructive sale of an appreciated financial position, the taxpayer generally recognizes gain as if the position were sold, assigned, or otherwise terminated at its fair market value on ...

The Internal Revenue Service is planning to require corporate taxpayers to provide brief descriptions of their uncertain tax positions along with the maximum amount of tax exposure if those positions ...

This article explores transfer pricing disputes with tax authorities and related disclosures in financial statements. Recent increases in companies’ risk exposure from these controversies have raised ...

High-net-worth taxpayers are increasingly seeking tax opinions to navigate complex tax positions and reduce risks. This ...

Companies take IRS budgets into consideration when developing their year-to-year tax strategies and take more aggressive tax positions when IRS budgets are smaller, and retreat to less risky tax ...