The U.S. Justice Department (DOJ) cited as substantive authority in a reply brief a tax law article co-authored by Andersen Managing Director Joe Calianno. In its reply brief filed in Amazon.com et. al. v. Commissioner, No. 17-72922, which is pending in the U.S. Court of Appeals for the Ninth Circuit, DOJ cited to "Calianno & Dokko, Foreign Goodwill & Going-Concern Value, Corporate Taxation, 2017 WL 3635344 (2017).”

Andersen Global enhances its platform in Peru as Picón & Asociados, a collaborating firm since 2018, becomes the latest member firm to join the global organization. The announcement comes on the heels of the most recent member firm addition in Mexico as Andersen Global continues to strengthen its presence in Latin America and provide a suite of global, integrated services.

The article "Tax Losses Related to the Russia-Ukraine War” is featured on LexisNexis Practical Guidance. Authored by Andersen Managing Directors Ellen MacNeil, Mary Duffy and Sid Luckenbach along with Senior Manager Deanne Morton, the article details how a business can determine if a casualty loss sustained as a result of the Russia-Ukraine War qualifies for a deduction on its U.S. federal tax return.

Since the passing of the Tax Cuts and Jobs Act in 2017, several states have enacted or are contemplating enacting pass-through entity taxes (PTETs) as workarounds to the $10,000 cap on the federal state and local tax deduction.

Taxpayers with audited financial statements (AFS) have new opportunities under the final Sec. 451 regulations to defer recognizing income under the Sec. 451(b) book acceleration rule (see this Tax Release for a summary of the final Sec. 451 regulations). Those taxpayers with unbilled revenue or contract assets on the GAAP balance sheet may be able to defer such revenue for tax purposes under the new guidance.

In some families, younger generations start private equity funds and raise capital from both family and outside investors.

In trust and estate tax planning, a well understood and often used tax saving transaction is the partial interest gift discount when a non-controlling partial (or fractional) ownership interest is gifted between family members. In this case, once the fair market value of 100% of the subject real estate portfolio is established, a discount study is performed for the partial interest of the ownership amount that is transferred via a gift.

As we enter the second quarter of 2022, businesses and their owners face a state of change, disruption and uncertainty on both the domestic and international fronts. Despite the pending developments that have the potential to impact tax planning opportunities and challenges in 2022, there are some areas where tax planning needs are clear and where taxpayers must give their immediate attention. To that end, below are several tax-related moves that business should consider in 2022 including amending returns to capture tax benefits from the pandemic, leveraging deductions that may soon expire, and planning around expired tax benefits and current legislative uncertainty.