IRS Closely Scrutinizes Gift Tax Transfers of Partnership Interests Transferring a partnership interest to family members can be an effective estate planning strategy, but these transactions receive significant IRS scrutiny. Gift tax consequences often depend on detailed valuation rules and the specific rights attached to the transferred interest. Because of this, partnership interest transfers require...

IRS Applies Strict Rules to Qualified Business Unit (QBU) Status For businesses with international operations, determining whether an activity qualifies as a Qualified Business Unit (QBU) can have significant tax consequences. However, QBU status is not automatic—even for foreign branches or operations. The IRS applies detailed statutory and regulatory requirements, making each determination highly dependent...

IRS Strengthens FATCA Compliance Requirements for International Financial Institutions FATCA (Foreign Account Tax Compliance Act) continues to impose strict compliance obligations on foreign financial institutions (FFIs) and certain non-financial foreign entities (NFFEs). Rather than relying on informal IRS guidance, taxpayers and financial institutions must now meet detailed registration, documentation, reporting, and certification requirements to maintain...

IRS Manufacturing Status Determinations Depend on the Facts Whether a business qualifies as a manufacturer for federal tax purposes is not determined by a single IRS definition. Instead, the answer depends on the specific tax provision involved and the facts surrounding the business’s activities. Because of this, obtaining advance certainty from the IRS is often...