The Treasury Department and the IRS have issued highly anticipated guidance in the area of stewardship expenses and R&D expenses. The 2019 Proposed Regulations also provide extensive guidance on ...

The Internal Revenue Service has issued final regulations to provide guidance on the allocation and apportionment of interest expense by corporations that own a 10 percent or greater interest in a ...

In response to comments, the Treasury and IRS made two important changes in the 2020 Final Regulations regarding stewardship expenses. First, the 2020 Final Regulations turn off the affiliated group ...

Taxpayers received guidance Tuesday on how to allocate and apportion deductions and creditable foreign taxes and on other issues relating to foreign tax and the foreign tax credit in final regulations ...

The IRS on Thursday proposed rules for the allocation and apportionment of expenses for purposes of determining the limitation on the foreign tax credit to reflect changes to the law made by the Tax ...

The Tax Lawyer the nation’s premier, peer-reviewed tax law journal is published quarterly. The Tax Lawyer endeavors to provide scholarly articles by notable tax attorneys and professors, key reports ...

Even if a will or trust does contain a tax-apportionment clause, directing payment of all taxes out of the residue may not be the best tax result for the beneficiaries and may not mirror the ...

Cost allocation serves several purposes. Also referred to as cost apportionment, this practice of identifying the source of an expense and assigning the cost accordingly is an important factor in ...

The First Appellate District affirmed a judgment. The court held that an out-of-state corporate taxpayer s futures trading activity warranted the application of an alternate formula for calculating ...

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