The IRC states that if there is a constructive sale of any appreciated financial position, such position is subsequently disposed of, and at the time of the disposition, the transaction resulting in ...

If there is a constructive sale of an appreciated financial position, the taxpayer generally recognizes gain as if the position were sold, assigned, or otherwise terminated at its fair market value on ...

This article explores transfer pricing disputes with tax authorities and related disclosures in financial statements. Recent increases in companies’ risk exposure from these controversies have raised ...

When it comes to completing a company’s often extensive financial reporting requirements, it is easy to lose sight of the impact those valuations may have on the company’s tax positions. However, ...