Foreign Gifts and IRS Reporting - U.S. persons who receive gifts or bequests from foreign persons beware—these gifts or bequests may need to be reported to the Internal Revenue Service (“IRS”). The consequences for failing...more
The sale of a computer program—it seems simple. But, as illustrated by the Treasury Regulations’ computer program characterization rules, the issue of just what a sale of computer program is can become confusing fast....more
On February 4, 2022, the Organization for Economic Cooperation and Development (“OECD”) issued model rules for nexus and revenue sourcing under Pillar One of the international tax agreement (the so-called “two-pillar...more
Hiya folks, and welcome to the inaugural installment of our new series giving you a quick recap of what’s happened in the world of Texas taxes in the month gone by. Let’s get started!...more
On January 25, 2022, the Internal Revenue Services issued final regulations relating to the treatment of stock owned by domestic partnerships under certain provisions of subpart F of the Internal Revenue Code (“Subpart F”). ...more
Created by Congress in 1971 as a tax incentive for domestic exporters of U.S.-made goods, the domestic international sales corporation (DISC) remains a viable tool for small-to-medium sized exporters to reduce their federal...more
Every few months or so seem to bring new revelations of a Ponzi scheme gone bust. In the aftermath, erstwhile investors often struggle to be made whole again. Fortunately, the federal income tax offers options to help,...more