No. 55-8, August 2024

Index

• A trust is not always a trust for federal income tax purposes.
• Academic research sheds light on important tax matters.
• Advances between affiliated entities: An uphill but winnable battle for loan characterization. (Allen v. Commissioner)
• Bitcoin ETFs: The known and unknown. (exchange-traded funds)
• Can a system of quality management in tax benefit everyone?
• Converting a rental or vacation home into a primary residence.
• Foreign partnership reporting requirements.
• Partnership distributions: Rules and exceptions.
• Partnership elected BBA procedures; TEFRA FPAA invalid. (Bipartisan Budget Act of 2015) (Tax Equity and Fiscal Responsibility Act of 1982 notice of final partnership administrative adjustment)
• Sec. 163(j) planning considerations. (Internal Revenue Code)
• Supreme Court: Obligation to redeem stock was not a liability. (Connelly v. Commissioner)
• The double-tax consequences of an S corporation subject to BIG tax. (built-in gains)
• The past, present, and future of the BBA partnership audit regime. (Bipartisan Budget Act of 2015)
• Wealth migration and change of domicile.