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IRS Anti-Abuse Doctrines: Economic Substance, Step Transaction, Substance over Form
Financial Analysis and Accounting
Aug 9
Corporate recapitalizations and tax-free exchanges (IRC § 351 and § 368)
Financial Analysis and Accounting
Aug 9
Partnership mergers and incorporation of partnerships into corporations
Financial Analysis and Accounting
Aug 8
Foreign Tax Credit Limitation Rules and FTC Baskets
Financial Analysis and Accounting
Aug 8
Use of Hybrid Entities and Hybrid Instruments in Tax Planning
Financial Analysis and Accounting
Aug 7
S Corporations vs. C Corporations: Tax Planning and Conversion Rules
Financial Analysis and Accounting
Aug 7
Corporate Liquidations under IRC § 331–§ 336
Financial Analysis and Accounting
Aug 6
Treatment of Distributions and Constructive Dividends
Financial Analysis and Accounting
Aug 6
Dividend Received Deduction (DRD) and Related Party Limitations
Financial Analysis and Accounting
Aug 5
Corporate Tax Consolidation Rules and Intercompany Transactions
Financial Analysis and Accounting
Aug 5
Loss Limitations and NOL Carryforwards Post-TCJA (IRC § 172 and § 382 limitations)
Financial Analysis and Accounting
Aug 4
Corporate Tax Implications of Stock vs. Asset Sales
Financial Analysis and Accounting
Aug 4
Tax Treatment of Mergers, Acquisitions, and Reorganizations (IRC § 368 series)
Financial Analysis and Accounting
Aug 3
Earnings Stripping Rules and Limitations on Interest Deductions (IRC §163(j))
Financial Analysis and Accounting
Aug 3
Corporate AMT (Alternative Minimum Tax) under the Inflation Reduction Act (2022 onwards)
Financial Analysis and Accounting
Aug 2
Taxation of Corporate Inversions and Anti-Inversion Rules
Financial Analysis and Accounting
Aug 2
Base Erosion and Anti‑Abuse Tax (BEAT)
Financial Analysis and Accounting
Aug 1
Global Intangible Low‑Taxed Income (GILTI) and Foreign‑Derived Intangible Income (FDII)
Financial Analysis and Accounting
Aug 1
Controlled Foreign Corporations (CFCs) and Subpart F Income
Financial Analysis and Accounting
Jul 31
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