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 ...

A concentrated stock position exists when a single stock makes up a disproportionately large share of total investable assets ...

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 ...

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 ...

FASB Interpretation no. 48 (FIN 48), Accounting for Uncertainty in Income Taxes, sets the threshold for recognizing the benefits of tax return positions in financial statements as “more likely than ...

When it comes to completing a company’s often extensive financial reporting requirements, it is easy to lose sight of the impact those valuations may have on the company’s tax positions. However, ...

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 ...