No. 56-2, February 2025

Index

• Mandatory basis adjustments for certain LLC transfers. (limited liability company)
• New IRS form for partners receiving property distributions.
• On DRD, the IRS seeks to have its cake and eat it too. (dividends-received deduction)
• Payments for law violation are not deductible restitution.
• States continue to tweak NOL provisions. (net operating losses)
• Tax considerations for foreign investment in US private credit.
• Tax Court again holds Sec. 6038(b) (1) penalties not assessable. (Internal Revenue Code)
• Tax Court limits discovery for sampled research credit claims.
• Taxpayer denied theft loss deduction for investment loss. (COLUMNTAX TRENDS)
• The CFC/PFIC overlap rule after aggregate treatment. (controlled foreign corporation/passive foreign investment company)
• Transfer pricing: The C-suite needs to be informed.
• Using role playing in a tax classroom.