The AICPA also proposes to coordinate the rules of subchapter J with subpart F by treating PTEP as distributed from the CFC ...

If the taxpayer has cost basis adjustments, the IRS requires Form 8949; listing each securities proceeds, cost basis, WS losses, and other cost basis adjustments. However, there’s a problem ...

The recommendations, sent Tuesday in a letter to Treasury and the IRS, include that the IRS expressly allow taxpayers to rely on proposed regulations until they are final.

But that use as well as use of tested losses of CFCs elsewhere in the group can cause two possibly offsetting adjustments to the basis of the group member’s stock. There is no need to detail ...

Moreover, under section 961(b)(2), if an amount that is excluded under section 959(a) exceeds the adjusted basis of the stock with respect to which it is received, the amount is treated as gain ...

Co-op Capital Expenditures: Apartment Tax Basis Adjustments In their Cooperatives and Condominiums column, Eva Talel and Richard Siegler write: One common mistake made by co-op apartment owners ...

procedure or regulation), it wouldn’t issue private letter rulings or determinations on whether assets in a grantor trust receive an Internal Revenue Code Section 1014 basis adjustment at the ...