- Journal of Accountancy
- ITR Direct Tax
- ITR Indirect Tax
- ITR Transfer Pricing
IRS announces terms of new conservation easement settlement opportunity
The terms of the new, time-limited settlement opportunity include the type and amount of deduction that eligible taxpayers will be allowed and the penalty rate that will apply.
AI for CPAs: From efficiency tool to decision engine
Most global finance leaders in a new survey report that artificial intelligence is improving decision-making and forecast accuracy in the finance function, and organizations using agentic AI and those making sure AI is assurance-ready are seeing bigger gains.
Another settlement offer planned in IRS conservation easement cases
With hundreds of cases in the courts, the IRS is preparing at least its fourth settlement offer in syndicated conservation easement cases in recent years.
CP53E notice tied to paper-check transition causes confusion
Taxpayers and practitioners are unsure whether the CP53E notices they have received are scams or simply sent in error, a confusion heightened by the inclusion of a QR code.
IRS establishes program for rulings on significant issues
The IRS is reinstating the practice of issuing these letters in response to numerous informal comments from taxpayers and practitioners regarding the time required to process letter ruling requests and the scope of those requests.
IRS announces terms of new conservation easement settlement opportunity
The terms of the new, time-limited settlement opportunity include the type and amount of deduction that eligible taxpayers will be allowed and the penalty rate that will apply.
Another settlement offer planned in IRS conservation easement cases
With hundreds of cases in the courts, the IRS is preparing at least its fourth settlement offer in syndicated conservation easement cases in recent years.
CP53E notice tied to paper-check transition causes confusion
Taxpayers and practitioners are unsure whether the CP53E notices they have received are scams or simply sent in error, a confusion heightened by the inclusion of a QR code.
IRS establishes program for rulings on significant issues
The IRS is reinstating the practice of issuing these letters in response to numerous informal comments from taxpayers and practitioners regarding the time required to process letter ruling requests and the scope of those requests.
COVID-19 disaster relief case has implications for timely refund claims
National Taxpayer Advocate Erin Collins explained what affected taxpayers need to do in response to the Court of Federal Claims’ holding that a taxpayer’s refund claim filing deadline was automatically extended by Sec. 7508A(d)(1) due to the COVID-19 disaster declaration.
VAT and transfer pricing: beyond the arm’s-length principle
The CJEU’s Stellantis ruling builds on recent case law concerning the VAT implications of transfer pricing adjustments and highlights an often overlooked interaction, says Fernando Matesanz of Spanish VAT Services
Intra-group guarantees and TP: Italian Supreme Court endorses a substance-based approach
Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine a recent decision concerning the transfer pricing treatment of non-remunerated intra-group guarantees, focusing on economic substance, legal form, and group-level business justifications
TP and the Corporate Tax Roadmap: reform by momentum, not revolution
Nearly two years after its publication, the Corporate Tax Roadmap is reshaping the UK’s TP framework through incremental reforms focused on scope, transparency and earlier HMRC intervention
Pillar two’s first compliance test: what advisers should be telling clients
With a stark divergence between MNEs that prepared early and those rushing to catch up, advisers must remain agile with all manner of compliance risks
Canada in midst of ‘exceptionally active period of tax reform’
The key changes under Budget 2025 and the outlook for 2026 raise several areas of heightened focus for taxpayers, say Matthew Kraemer, Adam N Unick, and Justin Ng of McCarthy Tétrault