Generally, partnerships whose interests are traded on an established exchange (or are readily tradable on a secondary market), known as publicly traded partnerships, are not entitled to the favorable pass-through treatment afforded to other non-publicly traded partnerships.

With the 2012 U.S. election in the rear-view mirror and the global economy sputtering along with modest projections for growth, now is a good time to dust off your foreign tax credit (FTC) calculations and get "back to basics" for 2013 and beyond.

Business restructurings achieve economic benefits through a broad array of strategies. Cost savings and operational improvements are often key drivers. The primary mechanisms used to achieve the company's goals involve the redeployment of functions, assets or risks. Therefore, a restructuring exercise may offer significant tax planning opportunities through transfer pricing.

he Internal Revenue Code is notorious for complicated rules, confusing provisions and differing interpretations of its most simple provisions. For example, the global interest netting provision in Section 6621(d) enacted in 1998 was recently subject to the same confusion that plagues so many other sections.

Between talk about the "fiscal cliff" and budget shortfalls, it is clear that Congress must act to move towards a balanced budget and reduce deficits.