May 11, 20221 min readDeductions are Allocated and Apportioned in Classes Existing in Year Taken (AM 2022-001, 5/6/2022) Taxpayers argue that deferred compensation expense earned prior to the enactment of 250(b) Foreign Derived Intangible Income should not...
May 4, 20211 min readAdditional Drafts of 2021 Schedules K2 and K3 Released Draft 2021 Schedules K2 and K3 Released (IR-2021-98; April 30, 2021) The IRS has released draft Schedules K-2 and K-3 for the Forms 1065,...
Feb 16, 20212 min readFinal Regulations Issued on Sourcing Rules for Sales of Inventory Property (T.D. 9921)The Sourcing Rules §861-865 The sourcing rules have an important purpose for US persons and non-US persons. Since a US person is taxed in...