Shows
Current Federal Tax Developments2025-08-11 IRS Announces No Payroll Changes for 2025This week we look at: Urgent Guidance Requested on Section 174A Domestic Research and Experimental Expenditures Post-Referral Authority in Tax Litigation—IRS Lacked Authority to Approve ERC Refund Closer This Time, But Still Not Quite There—Another Microcaptive Loss for the Taxpayers Proposed Amendments to IRC Section 132 Fringe Benefit Rules: Switching to NAICS Understanding Passthrough Losses and Bankruptcy in Field Attorney Advice 20253101F Proactive Engagement with the Office of Professional Responsibility IRS Announces Policy for the One Big Beautiful Bill Act for 2025 Payroll IssuesA...2025-08-1000 min
Current Federal Tax Developments2025-08-04 A Late Tax Season Start ExpectedThis week we look at:Filing Season Forecast to Start in Mid-February in the Coming SeasonSettlement Proceeds Found to Be Taxable and Taxpayer Stuck With Late-Filing PenaltiesIRS Issues Relief for Certain Issues Related to Partnership Investments and the Corporate Alternative Minimum TaxCorporate Mergers and the Same Taxpayer Rule for Interest NettingWhat Is an Educational Organization for Unrelated Business Income Tax (UBIT) Purposes?An audio only version of this week’s broadcast can be streamed or downloaded below:
A copy of the ar...2025-08-0200 min
Current Federal Tax Developments2025-07-21 Dealing with Uncashed Retirement Plan ChecksThis week we look at:Conservation Easement Deductions: A Critical Review of Rock Cliff Reserve, LLCPortability Election Pitfalls: A Deep Dive into Estate of Rowland and DSUE RequirementsUnderstanding Equitable Tolling in Tax Court: Insights from Boechler, P.C. v. CommissionerA Critical Review of Veribest Vesta, LLC v. Commissioner of Internal Revenue: Implications for Conservation Easement ValuationsUnderstanding Withholding and Reporting for Uncashed Retirement Plan Distribution Checks: A Review of Rev. Rul. 2025-15Fifth Circuit Affirms Tax Court’s Disallowance of Micro-Captive Insurance Deductions: An...2025-07-1900 min
Current Federal Tax Developments2025-07-14 Passage of a Much Shorter Additional Tax BillThis week we look at:Recent Developments: Interpreting the Johnson Amendment in Tax-Exempt Status LitigationAn Examination of Contract Formation in Tax Court Settlement: Insights from Arden Row Assets, LLCJurisdictional Imperatives in Tax Court: A Case Study on Timeliness and Last Known AddressExpanding Horizons: Potential Changes to Disaster Tax Relief Under the Filing Relief for Natural Disasters ActAn audio version of this week’s broadcast can be streamed or downloaded below
A PDF with this week’s articles can be downloaded via the link belo...2025-07-1400 min
Current Federal Tax Developments2025-07-07 Win Some Lose Some on Statutes of Limitations for the IRSThis week we look at:Bad Debt Deduction and Accuracy-Related Penalties: Key Takeaways from Anaheim Arena Management, LLC v CommissionerFBAR Compliance and the CPA’s Due Diligence Under Circular 230Dissecting Partnership Audit Limitations: Insights from JM Assets, LP v. CommissionerDecoding Penalty Assessments: A Deep Dive into Moxon Corporation v. CommissionerTax Court Scrutiny: Upholding Civil Fraud Penalties in Beleiu v. CommissionerAn audio only version of this week’s broadcast can be streamed or downloaded below:
A PDF of this week’s articles can be...2025-07-0700 min
Current Federal Tax Developments2025-06-30 ERC Issues Return to CourtThis week we look at:Court Upholds IRS’s Employee Retention Credit GuidanceTaxpayer Files in US District Court as the IRS’s Failure to Act on its Appeal Was Causing the Statute of Limitations to Run OutIRS Updates K-2 and K-3 Filing Requirements FAQ, Expands Exceptions to FilingTaxpayer Advocate Releases Fiscal Year 2026 Objectives Report to CongressTrust Fund Recovery Penalties: A Case Study on "Responsible Person" and "Willfulness" Under 26 U.S.C. § 6672An audio recording of this week’s broadcast can be streamed or downloa...2025-06-3000 min
Current Federal Tax Developments2025-06-23 Senate Finance Committee Tax Provision Draft IssuedThis week we look at:Schwartz v. Commissioner: The Critical Role of Estimated Tax Compliance in Collection Due Process DeterminationsCano v. Commissioner: Validity of Notice of Deficiency and Address ErrorsKey Differences Between House and Senate Tax Provisions in Reconciliation Process to DateAn audio only version of this week’s broadcast can be streamed or downloaded below.
A PDF of the articles for this week’s update can be downloaded below:2025-06-23 Current Federal Tax Developments2025-06-2300 min
Current Federal Tax Developments2025-06-16 The Case of the Vanishing LevyThis week we look at:Understanding Automatic Accounting Method Changes-Revenue Procedure 2025-23Accounting Method Changes in Conmac Investments, Inc.Conservation Easements in Glade Creek Partners, LLCTax Treaty Exemptions in Kramarenko v. CommissionerTax Refund Litigation & Variance Doctrine in Shleifer v. U.S.Tax Court Jurisdiction in Commissioner v. ZuchDigital Asset Reporting & Withholding in Notice 2025-33An audio only version of this week’s update can be streamed or downloaded below:
A PDF with articles on this week’s developments can...2025-06-1600 min
Current Federal Tax Developments2025-06-09 Worthlessness vs Cancellation of Debt Are Not the SameThis week we look at: Navigating Corporate Alternative Minimum Tax (CAMT) Conservation Easement Valuation & Penalties: A Warning from Tax Court Collection Due Process (CDP) & Offers in Compromise (OICs): Lessons from Tax Court Accuracy-Related Penalties: Navigating Negligence and Insufficient Professional Reliance Understanding Treasury’s Request for Information on Modernizing Federal Payments Worthlessness vs. Discharge: A Ninth Circuit Examination of Bad Debt Deductions Concurrent with COD Income Navigating the Religious Exemption Landscape: A Deep Dive into Unemployment Compensation TaxAn audio-only version of this week br...2025-06-0800 min
Current Federal Tax Developments2025-05-26 Second Challenge to Convenience of the Employer RuleThis week we look at:IRS Reduces Estate Tax Closing Letter FeeTax Court Scope of Review in Passport CasesMarital Deduction for Bequests to Trust“Reasonable Cause” in Late-Filing Penalty Cases“No Tax on Tips Act” (S.129) Passes SenateTransfer Pricing in Facebook, Inc. & Subsidiaries v. CommissionerNavigating New York’s Convenience Rule: Insights from Matter of ZelinskyAn audio only version of this week’s broadcast can be streamed or downloaded below.
A PDF with the text of articles on...2025-05-2700 min
Current Federal Tax Developments2025-05-19 Passthroughs and the One Big Beautiful BillThis week we look at:IRC Section 7433 and the Scope of the Collection Waiver of Sovereign ImmunityThe Claim of Right Doctrine Applied to Business ErrorsIRC Section 7433: Reinforcing Collection vs. Assessment DistinctionSelected issues from The One, Big, Beautiful Bill’s tax provisionsProposed Changes to the Section 199A Qualified Business Income DeductionProposed Changes Affecting Passthrough Entities and State PTE TaxesInterest Deductions and Penalties in Complex Financial TransactionsAn audio only version of this week’s update can be streamed or d...2025-05-1900 min
Current Federal Tax Developments2025-05-12 Taxpayer Fails to Qualify for Deduction for DoD Ordered MoveThis week we look at: Deductibility of IVF and Gestational Surrogacy Costs Fraudulent Tax Claims & 28 U.S.C. § 2514 Tax Collection Suits & Statute of Limitations in United States v. Ragen Moving Expense Deduction - Civilian Department of Defense Contractor Eligibility Tax Court Jurisdiction - The 90-Day Deadline for Deficiency PetitionsAn audio version of this week’s broadcast can be streamed or downloaded below
A PDF with this week’s articles can be downloaded below:2025-05-12 Current Federal Tax Developments2025-05-0900 min
Current Federal Tax Developments2025-05-05 Will We See PL 86-272 Finally Revised?This week we look at:ERC Claims Filed Without Schedule RReasonable Cause for Information Return Penalties: Reliance on SoftwareProposed Expansion of P.L. 86-272 "Solicitation of Orders" Definition2026 Inflation Adjustments for HSAs and Excepted Benefit HRAsAn audio only version of this week’s broadcast can be streamed or downloaded below:
A PDF with articles on this week’s updates can downloaded as a PDF below:2025-05-05 Current Federal Tax Developments2025-05-0200 min
Current Federal Tax Developments2025-04-28 Twice to the Supreme CourtThis week we look at:Navigating the Overlap: Civil Tax Assessments and Criminal Restitution OrdersNavigating Innocent Spouse Relief: A Look at Salvi v. CommissionerSupreme Court Weighs Tax Court Jurisdiction in Levy Disputes After Tax Payment: A Deep Dive into Commissioner v. ZuchNavigating ERISA Prohibited Transaction Claims: Insights from Cunningham v. Cornell UniversityAn audio version of this week’s broadcast can be streamed or downloaded below:
Articles on this week’s updates can be downloaded as a PDF below:2025-04-28 Current Fede...2025-04-2500 min
Current Federal Tax Developments2025-04-21 Hobby Horse ProblemsThis week we look at:Navigating the 90-Day Deadline for Employment Tax Redeterminations: The Belagio Fine Jewelry, Inc. Case and Equitable TollingGWA, LLC v. Commissioner: Substance Over Form and the Nuances of Tax Elections for Disregarded EntitiesNotice 2025-23: Treasury and IRS Signal Withdrawal of Basis Shifting TOI Regulations and Related PenaltiesHobby Loss and Failure to File: A Deep Dive into Himmel v. CommissionerAn audio version of this week’s broadcast can be streamed or downloaded below:
Articles on this week’s developments can be d...2025-04-1800 min
Current Federal Tax Developments2025-04-16 A Very Busy Week as the Deadline ApproachedThis week we look at:Massachusetts Source Income and the Sale of Stock by a NonresidentNavigating the Valuation Landscape: Insights from Pierce v. CommissionerPersonal Liability for Corporate Sales and Use Tax: An Analysis of Matter of the Appeal of B. WagemanNavigating the IRS’s ERC Claim Processing Moratorium and "Risking" ProceduresJurisdictional Prerequisites in Tax Refund Suits: A Case Study of Estate of Robert F. Armitage, Deceased v. The United StatesDependency Claims and Child Tax Credits: A Look at Correll v. Commissioner2025-04-1600 min
Current Federal Tax Developments2025-04-07 The Cost of Too Good to Be TrueThis week we look at:Ranch Springs, LLC v. Commissioner: A Case Study in the Valuation of Conservation Easements and the Pitfalls of Aggressive Tax PlanningThe Duty of Consistency Prevails: A Case Study in Innocent Spouse Relief and Subsequent Asset ClaimsNavigating the Murky Waters of Investment Tax Credits and Passive Activity Rules: A Deep Dive into Strieby v. CommissionerAn audio only broadcast can be downloaded or streamed below:
Articles on this week’s developments and citations can be downloaded below:2025-04-07 Current Federal Ta...2025-04-0600 min
Current Federal Tax Developments2025-03-31 End of Paper Tax Payments and Refund Checks ComingThis week we look at:Congress Passes Resolution to Nullify Final Regulations on DeFi Information Reporting in TD 10021Interim Final Rule Limiting BOI Filing Requirements Released by Treasury DepartmentSubstantiating Depreciation for Converted Property: A Look at Smith v. CommissionerExecutive Order Will Generally Bar the Use of Paper Checks to Make Payments to or Receive Refunds from Treasury, Including Tax Related OnesJones et al. v. Commissioner: A Deep Dive into the Tax Court’s Scrutiny of a Microcaptive Insurance ArrangementNavigating Jurisdictional Hurdles in Tax Re...2025-03-3000 min
Current Federal Tax Developments2025-03-24 ERC Simplified Method for Income Tax ReportingThis week we look at:TIGTA Report: IRS Refund Claim Processing for Deceased TaxpayersIRS Certification of Seriously Delinquent Tax Debt to the State DepartmentRefund Claim Challenges: When IRS Guidance FailsSixth Circuit: IRA Forfeiture to Government Not TaxableLoper Bright: Pharmacy Benefit Managers Denied DPAD DeductionIRS ERC Update: Simplified Income Tax Reporting for Wage ReductionAn audio only version of this week’s broadcast can be streamed or downloaded below:
The articles for this week’s developments can be downloaded belo...2025-03-2400 min
Current Federal Tax Developments2025-03-17 IRS Guidance on When a Scam Generates a Theft DeductionThis week we look at:Tax Court Finds Taxpayer Failed to Provide a Qualified Appraisal, No Charitable Deduction AllowedEstate Found Liable for $2 Million FBAR Penalty That Applied to the DecedentTaxpayers Filing Court Challenges to Attempt to Obtain Employee Retention Tax CreditsFourth Circuit Overturns Trial Court’s Grant of Summary Judgment to the Government, Finding True Issue of Fact Exists Regarding Whether Statute Remained OpenIRS Memorandum Discusses When a Taxpayer Can Claim a Deduction as Victims of Various Scams Under Current LawAn audio on...2025-03-1600 min
Current Federal Tax Developments2025-03-10 Can We Mostly Ignore BOI NowThis week we look at:Treasury and the Corporate Transparency Act (BOI Reporting)Martino v. Commissioner: Alimony Deduction CaseEstate of Kalikow v. Commissioner: Estate Tax & Settlement PaymentsAppeal of A. Markowski: California Source Income for NonresidentsCF Headquarters Corporation v. Commissioner: Taxability of GrantsUnited States v. Gora: IRS Levy EnforcementAn audio only version of this week’s broadcast can be downloaded or streamed below:
Articles for this week’s developments can be downloaded from the link below:2025-03-10...2025-03-0900 min
Current Federal Tax Developments2025-03-03 FinCEN Announces BOI Relief and Future ActionsThis week we look at:FinCEN Announcement on BOI Reporting PenaltiesTax Court Case: Alan Hamel and Estate of Suzanne Hamel v. CommissionerIRS “Dirty Dozen” Tax Scams for 2025IRS Adds Tax Documents to Online AccountsWays and Means Committee Passes Disaster Relief BillsHouse and Senate Budget ResolutionsAn audio only version of this week’s broadcast can be downloaded or streamed below:
A copy of the articles for this week’s broadcast can be downloaded below:2025-03-03 Current Federal...2025-03-0200 min
Current Federal Tax Developments2025-02-24 BOI Developments WeekThis week we look at:Second Circuit Rules on Section 179D Deductions and Accounting Method ChangeIRS Guidance on ACA Notice PostingCourt Case on CPA Negligence and Trust Return PenaltiesBOI Reporting Requirement UpdatesAn audio only version of this week’s broadcast can be downloaded below:
The articles and citations for this week’s broadcast can be downloaded as a PDF from the link below:2025-02-25 Current Federal Tax Developments2025-02-2300 min
Current Federal Tax Developments2025-02-17 A Week of Lost LossesThis week we look at: Deductibility of Losses: Weston v. Commissioner Conservation Easements: Green Valley Investors LLC Automobile Depreciation and Lease Inclusion S Corporation Inadvertent Termination Relief Corporate Transparency Act (CTA) - Government Briefs House Ways & Means Committee Tax BillsAn audio only version of this week’s broadcast can be streamed or downloaded below;
The articles for this week’s update can be downloaded below:2025-02-16 Current Federal Tax Developments2025-02-1600 min
Current Federal Tax Developments2025-02-10 New Administration Pushes Foward with the CTAThis week we look at:
IRS issues letter ruling on IRA left to trust
A taxpayer mistakenly believes the IRS had conceded that his income was not subject to self-employment tax, but it hadn’t
The Tax Court denies a taxpayer’s deductions and claimed partnership losses due to incredibly disorganized and inadequate records
Taxpayer runs afoul of the “pay first, litigate later” rule when attempting to sue the IRS for a refund in US District Court in response to an assessment
A taxpayer’s unprocessed claim for an ERTC refund doesn’t justify CDP relief
The BOI - new Admini...2025-02-0800 min
Current Federal Tax Developments2025-02-03 A Week of Tax Court RulingsThis week we look at:Tax Court Finds Property Donated to Charity Had a Value Less than One-Third of What Taxpayers Claimed on ReturnIRS Finds Most Expenses Related to Taxpayers’ In Vitro Fertilization and Surrogacy Will Not Be Deductible Medical Expenses Under IRC §213Taxpayer Denied Innocent Spouse Relief in Tax Court Bench OpinionTax Court Finds No Issue With the Appeals Office Structure and StaffingFailure to Provide Proof of Filing of Returns Fatal to Taxpayer’s Attempt at Obtaining Relief in CDP Hearing Despite IRS Procedural Errors2025-02-0200 min
Current Federal Tax Developments2025-01-27 BOI Sees Supreme Court Action But There a CatchThis week we look at:Funds Taken By Sheriff Were a Valid Loan and Not Income from EmbezzlementTax Court Allows a Reduced Deduction for a Conservation EasementCCA Discusses Issues with Activities of a Private Foundation with Regard to Self-Dealing, Attempted Correction and Jeopardizing InvestmentsIRS Email Discusses Agency’s (Lack of) Obligation to Process Amended Tax ReturnsSupreme Court Reverses Fifth Circuit Merits Panel, Again Removes Emergency Injunction Against Enforcement of the CTA BOI ReportsDespite Supreme Court’s Action on Texas Top Cop Shop...2025-01-2600 min
Current Federal Tax Developments2025-01-20 SECURE 2.0 Act Proposed GuidanceThis week we look at:IRS updates residential energy credit Fact Sheet, adds details about the PIN requirements that take effect for 2025 propertyProposed regulations on catch-up contributions added by the SECURE 2.0 ActProposed regulations on the automatic enrollment provisions of IRC §414AUS Supreme Court agrees to review a Third Circuit ruling on Tax Court jurisdiction in a Collection Due Process caseIRS issues final regulations on resolution of tax controversies by the IRS Independent Office of Appeals Under TFA of 2019An audio only verison of t...2025-01-1900 min
Current Federal Tax Developments2025-01-13 Tax Filing and Payment Relief for California Wildfires and MoreThis week we look at:IRS Grants Tax Relief to California Wildfire VictimsNational Taxpayer Advocate’s Report to Congress and Legislative Recommendations ReleasedThird US District Court Issues BOI Reporting InjunctionTax Court Finds a Building Was Not a Certified Historic Structure as Defined by §170(h)Taxpayer Denied Refund as Court Found the Taxpayer Had Taken the Position That Its Reporting Was an Error Rather Than a Method of AccountingSeventh Circuit Upholds Imposition of Fraud Penalty for an Overstatement of WithholdingsCourt Finds Tax...2025-01-1200 min
Current Federal Tax Developments2025-01-06 Digital Assets, BOI, Conservation Easements and EmbezzlementThis week we look at:IRS gives relief for specific identification of digital asset basis for certain taxpayers for 2025 onlyDepartment of Justice asks the U.S. Supreme Court to Stay the Latest Corporate Transparency Act InjunctionIRS no longer to dispute requirement to comply with APA to add listed transactions after the enactment AJCA in 2024Tax Court rules that merely being in a registered historic area does not make a building a certified historic structureTax Court finds taxpayer owes tax on over $5.3 million diverted from two retirement...2025-01-0500 min
Current Federal Tax Developments2024-12-30 BOI Developments - The Gift That Keeps on GivingThis week we look at:Tomato processing plant reconditioning to put plant back into shape before beginning next harvest-season production failed all events test at end of the prior seasonTax Court again imposes functional test in case with state law limited partnersThe BOI reports have a week of dueling court rulings - from the same courtAn audio only version of this week’s broadcast can be streamed or downloaded below.
A PDF with the slides and citations for this week can be downloaded below:2024-1...2024-12-2800 min
Current Federal Tax Developments2024-12-24 IRS Proposes Signficant Revisions to Circular 230This week we look at:Automatic accounting method changes related to §174 extended to years beginning in 2024BOI report - hectic week, but ultimately no resolution yet for initial report due date2025 mileage rates published by the IRSIRS finalizes regulations on supervisory approval of penaltiesIRS proposes revisions to Circular 230An audio only version of this week’s broadcast can be streamed or downloaded below:
A PDF with the slides and citations can be downloaded viaa the link below:2024-12-23 Current Federal Tax...2024-12-2200 min
Current Federal Tax Developments2024-12-16 IRS Expands Business Tax Accounts Features and AccessThis week we look at:President signs the two tax bills Congress recently passedDOJ asks for stay of injunction issued by US District Court in Texas on enforcement of the CTAIRS expands Business Tax Account access and services that can be accessed via that account
A PDF of this week’s slides and links to the cited documents can be downloaded below.2024-12-16 Current Federal Tax Developments2024-12-1400 min
Current Federal Tax Developments2024-12-09 Nationwide Injunction on BOI ReportingThis week we look at:Congress enacts two tax laws: but neither is the big one that passed the House in January but stalled in the US SenateA Texas US District Court has issued a nationwide temporary injunction barring FinCEN from enforcing the BOI reporting regimeDOJ files a notice of Appeal of the Texas Top Cop Shop Inc decision and FinCEN posts information regarding the impact of the case on BOI reportsAn audio only version of this week’s broadcast can be streamed or downloaded below:
A...2024-12-0800 min
Current Federal Tax Developments2024-12-02 New Form for 83b ElectionsThis week we look at:IRS releases optional form taxpayer can use to make an IRC §83(b) electionIRS extends for one year more a transitional 45-day period to perfect research credit claims found to be invalid claimsIRS provides additional relief on the issuance of Forms 1099-KAn audio only version of this week’s broadcast can be streamed or downloaded below:
A PDF with slides and the citations for this week’s broadcast can be downloaded below.2024-12-02 Current Federal Tax Developments2024-11-3000 min
Current Federal Tax Developments2024-11-25 IP-PINs, Divorced Parents and ChildrenThis week we look at:IRS announces program using IP-PIN to allow taxpayers who find a dependent on their return has already been listed on another to get their return processed immediatelyThe ERC Second Voluntary Disclosure Program ends but the IRS gives some additional relief for withdrawing a claim filed via third-party payer such as a payroll serviceAn audio only version of this week’s broadcast can be streamed or downloaded below.
A PDF with this week’s slides and citations can be downloaded below.2024-11-25 Curr...2024-11-2500 min
Current Federal Tax Developments2024-11-18 End of Partnership Suspense Account at the IRSThis week we look at:IRS may stop putting “taxpayer may rely” statements on proposed regulationsTax Court rules partnership basis calculations are cumulative in nature and not stand-alone annual calculations under IRC §705 Latest speculations on what will get through Congress in 2025 - if anythingAn audio only version of this week’s broadcast can be streamed or downloaded below:
A PDF of this week’s slides and links to supporting documents can be downloaded below:2024-11-18 Current Federal Tax Developments2024-11-1700 min
Current Federal Tax Developments2024-11-11 Post Election Issue on Tax Bills and the Reconciliation ProcessThis week we look at the rules involving the reconciliation process in Congress, the path that it appears most likely any tax bill enacted to deal with the expiration of many TCJA provisions at the end of 2025.An audio version of this week’s broadcast can be streamed or downloaded below
The slides for this week’s broadcast can be downloaded from the week below.2024-11-11 Current Federal Tax Developments2024-11-1000 min
Current Federal Tax Developments2024-11-04 Retirement Plan Inflation NumbersThis week we look at:Retirement plan limits announced by the IRS, basically completing the tax inflation adjustments for 2025IRS emailed Chief Counsel Advice outlines dealing with SECA and the net investment income tax issues arising from a BBA partnership examAn audio only version of this week’s broadcast can be streamed or downloaded below.
A PDF with copies of the slides and links to the authorities cited can be downloaded below:2024-11-04 Current Federal Tax Developments2024-11-0400 min
Current Federal Tax Developments2024-10-28 IRS Releases Most 2025 Inflation Adjusted NumbersThis week we look at:IRS releases inflation adjusted numbers for most items aside from retirement plans for 2023IRS has more bad news for those who fail to pay over trust fund taxes to pay other expensesAnother US District Court denies a preliminary injunction to bar enforcement of the BOI reporting rulesYou can stream or download an audio version of the broadcast below.
A PDF of the slides and documents can be downloaded as a PDF via the link below:2024-10-28 Current Federal Tax...2024-10-2700 min
Current Federal Tax Developments2024-10-21 Staking Returns for One More Try at CourtThis week we look atS corporation finds multiple ways to terminate its S status, asks IRS forgiveness which is grantedIRS rules condoms are medical expenses for tax purposesIRS adds items to list of preventive care an HDHP can pay without the insured having met the annual deductiblePTIN registration opens for 2025Staking income challenge returns to courtAn audio version of this week’s broadcast can be downloaded or streamed below
A copy of the slides and citations can be downloaded via th...2024-10-2100 min
Current Federal Tax Developments2024-09-09 More BOI Report IssuesThis week we look at:Additional BOI clarifications from online discussions regarding a CPA firm’s reporting obligations and confusions about reporting by entities that don’t register with a state for formation but which do file tax returnsAn audio only version of this week’s broadcast can be streamed below:
The slides and citations for this week’s broadcast can be downloaded as a PDF below.2024-09-09 Current Federal Tax Developments2024-09-0900 min
Current Federal Tax Developments2024-09-03 BOI Review TimeThis week we look at:DOJ has scheduled a December 2 hearing on the proposed rule to reschedule marijuanaBOI reporting confusions that keep coming up as questions in online discussions - time to reviewAn audio only version of this week’s broadcast can be streamed or downloaded below
A PDF with this week’s slides and citations can be downloaded below.2024-09-03 Current Federal Tax Developments2024-09-0200 min
Current Federal Tax Developments2024-08-26 IRS ERC Notices of Denial Comments of the Taxpayer AdvocateThis week we look at:IRS announces the reopening of the ERC Voluntary Disclosure Program on somewhat less generous terms then the first program providedNational Taxpayer Adviser discusses issues related to ERC Notices of Disallowance issued by the IRSAn audio only version of this week’s update can be streamed or downloaded below
A PDF with slides and this week’s links to cited documents can be downloaded below.2024-08-26 Current Federal Tax Developments2024-08-2400 min
Current Federal Tax Developments2024-08-12 Internet Frauds and Section 165This week we look atOnline scams and tax deductions - why how that online scammer you found on a dating site manages to take your money can make a big tax differenceIRS announces next steps in ERC program, will begin sending some checks in SeptemberAn audio only version of this week’s session can be downloaded and streamed below:
A PDF with copies of the slides and citations can be downloaded below:2024-08-12 Current Federal Tax Developments2024-08-1200 min
Current Federal Tax Developments2024-08-05 House Passed Tax Bill Fails to Clear Cloture Vote in the SenateThis week we look at: Tax bill fails to clear a procedural vote in the Senate, reducing the likelihood we’ll see the bill enacted before this Congress leaves officeUS District Court declines to issue preliminary injunction requiring the IRS to terminate the ERC claim moratorium, but finds much the court liked in the plaintiff’s arguments.An audio version of this week’s broadcast can be streamed or downloaded below:
A PDF with this week’s slides and citations can be downloaded from the link below.2024-08-05 Curre...2024-08-0500 min
Current Federal Tax Developments2024-07-29 More IRS ERC GuidanceThis week we look at:FinCEN adds two more questions to BOI FAQ pageIRS adds five new warning signs for problematic ERC claims and announces new developments coming in ERC enforcementChief Counsel Memorandum outlines position on tax exempt organizations dealing with §52 provisions for ERCAn audio only broadcast can be streamed or downloaded below:
A copy of the sides and links to the cited documents can be downloaded as a PDF below:2024-07-29 Current Federal Tax Developments2024-07-2900 min
Current Federal Tax Developments2024-07-22 IRA Finalizes RMD RegulationsThis week we look at:Taxpayer can’t simply rely on tax software when preparing their return, even if they aren’t being nominated for Secretary of TreasuryIRS finalizes SECURE Act/SECURE 2.0 Act required minimum distributions regulationsIRS proposed regulations address the problem of determining the applicable age for those born in 1959An audio only version of this week’s broadcast can be downloaded or streamed below
A PDF with the citations for this week’s podcast can be downloaded below:2024-07-22 Current Federal Tax Developm2024-07-2200 min
Current Federal Tax Developments2024-07-15 BOI UpdatesThis week we look at:FinCEN updates the FAQs for BOI reporting, adding information about entities that cease to existNew Jersey Committee on Unauthorized Practice of Law releases letter outlining when CPAs and EAs may prepare and/or file BOI reports for clients without the assistance of an attorneyAnother PLR issued for missed ESBT elections for trusts that qualified to make such electionsAn audio only version of this week’s broadcast can be streamed or downloaded below:
A PDF with the slides and citations for this we...2024-07-1400 min
Current Federal Tax Developments2024-07-08 Supreme Court Makes It Easier to Challenge RegulationsThis week we look atEnd of term US Supreme Court cases that will likely impact challenges to Treasury regulations, overturning the concept of Chevron deference and extending the statute to challenge regulations under the Administrative Procedures ActAn audio only version of this week’s broadcast can be streamed for downloaded below:
A PDF with a copy of this week’s slides and citations can be downloaded below:2024-07-08 Current Federal Tax Developments2024-07-0800 min
Current Federal Tax Developments2024-07-01 IRS to Eventually Automate FTA ReliefThis week we look at: Ninth Circuit rules that statute of limitations for the IRS to sue for recovery of erroneous refund begins when the check clears the Federal Reserve and is approved for payment by the US Treasury IRS National Taxpayer Advocate announces the IRS will automate FTA abatement of penalties beginning in 2026 Attorneys report some ERC claimants now interesting in filing suit to accelerate their claim processingAn audio version of this week’s braodcast can be streamed or downloaded below.
A PDF with the slides and ci...2024-07-0100 min
Current Federal Tax Developments2024-06-24 Supreme Court Upholds the 965 Transition TaxThis week we look at:Supreme Court rules, in a more divided than it may appear opinion, that the §965 transition tax is Constitutional, sustaining the result from the Ninth Circuit in the Moore case.IRS gives interim guidance for special distribution relief in the SECURE Act 2.0 for certain distributions.IRS indicates it will now be (slowly) processing ERC claims, vast majority show issuesAn audio only version of this week’s broadcast can be downloaded or streamed below:
A PDF with the citations and copy of the slides for thi...2024-06-2400 min
Current Federal Tax Developments024-06-17 Do Not Believe Your Chatbot on Tax MattersThis week we look at:IRS provides last minute relief for payment of second quarter corporate estimated tax payments related to corporate alternative minimum taxEn-banc rehearing request denied in case of Farhy v. Commissioner by DC CircuitCPA pleads guilty to tax charges related to syndicated conservation easement programTaxpayer Advocate warns of relying on generative AI for answering tax questions for consumer tax software - and there are just as big of issues for tax professionalsAn audio only version of this week’s broadcast can be do...2024-06-1700 min
Current Federal Tax Developments2024-06-10 Estate Tax Problems for Buy Sells Funded by Life InsuranceThis week we look at:US Supreme Court rules that a requirement to redeem the decedent’s shares cannot be considered to reduce the value of the entity, but life insurance proceeds received by the entity to fund the buyout will increase the valueTaxpayer denied relief for late rollover when funds were accidentally transferred from employer plan to Roth IRAIRS rules certain payments related to East Palestine, Ohio derailment are §139 disaster paymentsWhat options exist for an employer with a pending ERC claim?An audio only broadcast for...2024-06-0900 min
Current Federal Tax Developments2024-06-03 LLC as an S Corporation IssueThis week we look at:IRS announces that Direct File will continue into 2025 and be expanded while maintaining other programsA taxpayer finds its not so simple as just file a Form 2553 if you want to have an LLC taxed as an S corporation, but did realize the error fast enough to get a PLR to restore S statusAn audio only version of this week’s broadcast can be downloaded below
A copy of the slides and this week’s link to items mentioned can be downloaded below:2024-06...2024-06-0300 min
Current Federal Tax Developments2024-05-27 Misleading Silences Are Sometimes Fine in TaxThis week we look at:Yet another PLR requested for missed QSST election after S shares moved to trust following death of a shareholderTax preparer’s conviction for willfully filing false returns upheld on appeal despite his argument he had doing what he did for yearsLetters to taxpayer from IRS Appeals did not extend the time to file suit for a claim for refundA partnership had properly elected to use BBA audit provisions early, rendering IRS FPAA invalidAn audio only update for htis week’s sess...2024-05-2700 min
Current Federal Tax Developments2024-05-20 ERC Battles ContinueThis week we look at:DOJ issues proposed rule that would remove cannabis businesses from loss of most business deductions under IRC §280EFiling date relief issued for those impacted by Ohio tornadoes from MarchIRS National Fraud Counsel speaks on ERC exams in ABA Tax Section webinarTax adviser files suit to attempt to force the IRS to start processing ERC claimsTax Court imposes penalty for raising frivolous claims against taxpayer who argued wages are not income (among other things)An audio only version of t...2024-05-1700 min
Current Federal Tax Developments2024-05-13 Changes to CAFs and Process for Tax Pros to Obtain TranscriptsThis week we look at:IRS gives update on final results for ERC voluntary compliance program and discusses the futureThe taxpayer’s contract did not make payment contingent on the success of researchDOJ announces CPA firm barred from promoting CRAT/single premium annuity shelterIRS provides information on CAF “under review status” and changes to requesting transcriptsAn audio only version of this week’s update can be streamed or downloaded below.
A PDF containing copies of this week’s slides and links to documents cited this...2024-05-1300 min
Current Federal Tax Developments2024-05-06 IRS Can Assess Penalties for Failure to File Form 5471 per DC CircuitThis week we look at:IRS releases Fact Sheet on disaster provisions for retirement accounts added by SECURE 2.0 ActDC Circuit reverses Tax Court ruling that IRS does not have assessment authority for failure to file a report under IRC §6038(b) (Form 5471)Electric vehicle final regulations issuedDepartment of Justice begins process to move marijuana from Schedule I to Schedule III which would cause §280E to no longer limit deductions for cannabis businessesLack of any written records on time President/COO spent on activities or even estimate time sp...2024-05-0500 min
Current Federal Tax Developments2024-04-29 No Minimum Attention Required for Supervisor Approval of Penalties per Tax CourtThis week we look at:Final regulations issued on credit transfer provisions of the Inflation Reduction ActTax Court rules the law does mandate a minimum level of attention by a supervisor when approving a proposed penaltyIRS announces the end of the Direct File pilot and will announce the next steps shortlyAn audio only version of this week’s broadcast can be streamed or downloaded below.
A PDF with this week’s slides and links to citations can be downloaded below.2024-04-29 Current Federal Tax...2024-04-2800 min
Current Federal Tax Developments2024-04-22 IRS Extends Limited RMD Relief But Warns They Expect This to Be the Last TimeThis week we look at:IRS again waives penalties for certain RMD distributions for inherited IRAs and retirement plans, but indicates this should be the last timeFinCEN adds more Q&As to BOI FAQ for the first time since JanuaryAn audio only version of this week’s update can be streamed or downloaded via the link below.
Slides and links to the source documents can be downloaded as a PDF via the link below.2023-04-22 Current Federal Tax Developments2024-04-2000 min
Current Federal Tax Developments2024-04-01 Tax Court Reverses Position on Validity of Conservation Easement RegulationThis week we look atTax Court reverses position on validity of a regulation it had upheld four years agoUS Supreme Court hears oral arguments in case involving estate tax value of a corporation that received life insurance to redeem the majority shareholder’s estateIRS Criminal Investigation Divisions announces update on COVID relief related investigations and convictionsAn audio only version of this week’s session can be downloaded or streamed below
A PDF with the links and slides can be downloaded below:2024-04-01 Curr...2024-03-3100 min
Current Federal Tax Developments2024-03-25 ERC Voluntary Disclosure Program Is Over - What NextThis week we look at:As ERC voluntary compliance program ended, IRS release discusses agency’s plans going forwardSenate Finance Chair Wyden indicates there be a cloture vote in the Senate on House passed tax billIRS issues proposed regulations to make SPA CRAT arrangements listed transactionsIRS asks Supreme Court to overturn Culp decisionAn audio only version of this week’s broadcast can be streamed or downloaded below.
A PDF of the slides and citations for this week’s broadcast can be downloaded below:...2024-03-2400 min
Current Federal Tax Developments2024-03-18 Last Call to Enter ERC Voluntary Disclosure ProgramThis week we look at: FinCEN gives formal notice of appeal of CTA BOI case Deadline rapidly approaching for entering first ERC voluntary disclosure program Arizona lawmakers write the IRS about tax status of 2023 state rebates Court of Appeals finds it is barred from hearing appeal of Tax Court dismissal of small case/
The slides and citations for this week’s broadcast can be downloaded in the PDF below:2024-03-18 Current Federal Tax Developments2024-03-1700 min
Current Federal Tax Developments2024-03-11 FinCEN Announces Enforcement Reaction to Alabama CaseThis week we look at:FinCEN announces position on handling BOI enforcement following National Small Business United v. YellenIRS issues warning about companies peddling “doctor’s notes”Tax Court warns taxpayer about litigating an issue the taxpayer had previously litigated and lost on for a prior yearAn audio only version of this week’s broadcast can be streamed or downloaded below
A copy of the slides and links to citations can be downloaded below:2024-03-11 Current Federal Tax Developments2024-03-1000 min
Current Federal Tax Developments2024-03-04 Court Questions Constitutionality of the CTAThis week we look at:CTA found to violate Constitution by US District CourtTax Court issues ruling on impact of SECURE 2.0 Act statute change on returns filed before December 29, 2022 effective date of the ActIRS warns about need to reconcile premium tax credit on Forms 1040 after seeing an increase in the number of returns being filed without the required reconciliation
Citations and slides for this week’s update can be downloaded below:2024-03-04 Current Federal Tax Developments2024-03-0300 min
Current Federal Tax Developments2024-02-26 More BOI Information from InsurerThis week we look at:More BOI resources from CAMICO made available by NJCPADistrict Court refuses to stay FBAR proceeding to await Tax Court result partially due to the age of the taxpayerIRS announces program to go after corporate jet personal usageThe state of Arizona sues the IRS over tax status of state tax rebate.An audio only version of this week’s broadcast can be streamed or downloaded below:
This week’s slides and links to source documents can be downloaded below:2...2024-02-2600 min
Current Federal Tax Developments2024-02-19 Insurers Update BOI GuidanceThis week we look at:Insurers updating their advice on BOI engagementsSALT cap 2023 increase bill fails on a procedural vote in the HouseJury finds taxpayer did not willfully fail to file FBAR reportsIRS takes position third party payors liable for ERC refund repayment in addition to common law employersIRS sending out CP271 “soft letters” to those with open ERC refund claimsS corporation has a failure of 9 trusts receiving shares from decedentTaxpayer unsuccessfully argues she only should pay taxes on soci...2024-02-1800 min
Current Federal Tax Developments2024-02-12 Are You Giving Bad Advice on Electronic Filing?This week we look at No movement on tax bills this week - nor is final action at all likely to take place before March E-Filing returns - good or bad idea? Two competing articles published this week Taxpayer owes tax on IRA forfeited to government as part of criminal conviction IRS discusses when CID voluntary disclosure program should be used instead of ERC voluntary disclosure program IRS warns about EFIN scam emails Taxpayer found to have submitted a late new refund claim rather than a revision...2024-02-1000 min
Current Federal Tax Developments2024-02-05 More Movement on Proposed Retroactive Tax BillsThis week we look at: Bipartisan extender bill is passed by the House, but faces uncertain future in the Senate A limited, single-year SALT cap relief bill will be brought to the House floor as part of the compromise to pass the bipartisan bill Tax filing season for 2023 return begins this week A cautionary tale about phishing being used to obtain client tax informationAn audio only of this week’s broadcast can be streamed or downloaded below:
The slides and links to information are available to do...2024-02-0500 min
Current Federal Tax Developments2024-01-29 Bipartisan Retroactive Tax Bill Clears Ways and Means CommitteeThis week we look at a proposed tax bill that has advanced out of the House Ways & Means Committee.An audio only version of this week’s broadcast can be downloaded or streamed via the link below:
A copy of the slides with links to materials can be downloaded below.2024-01-29 Current Federal Tax Developments2024-01-2800 min
Current Federal Tax Developments2024-01-16 Form 8308 ReliefThis week we look at:Talks continue on proposed tax billIRS provides guidance on Pension-Linked Emergency Savings Account anti-abuse provisionsRelief granted for filing information found in Part IV of Form 8308 for 2023 returnsIRS updates Notice describing how to obtain certain exemptions from the required electronic filing of certain entity information and tax returnsAn audio only version of this week’s broadcast can be downloaded below:
The citations for this week’s program can be downloaded below:2024-01-16 Current Federal Tax Developments2024-01-1400 min
Current Federal Tax Developments2024-01-08 IRS Mistake Stands as Taxpayer BenefitsThis week we look at: New work in progress to try and obtain a bipartisan tax bill IRS gives car dealers a brief extension to file time-of-sale reports IRS reverses direction on treatment of impact of adding a tax reimbursement clause to an IDGT Taxpayer can rely upon date IRS places in Notice of Deficiency as the last day to file a Tax Court petitionAn audio only version of this week’s podcast can be downloaded or streamed below.
Articles on this week’s updates can be d...2024-01-0700 min
Current Federal Tax Developments2024-01-02 FinCEN Welcomes 2024 By Opening BOI Filing SiteThis week we look at FinCEN's release of the BOI E-Filing site on January 1, 2024.An audio only version of this week’s broadcast can be streamed below
A copy of this week’s slides and the BOI form can be downloaded via the links below:2024-01-02 Current Federal Tax DevelopmentsFinCEN Beneficial Ownership Information Form2024-01-0100 min
Current Federal Tax Developments2023-12-26 IRS Plays Santa With Two Relief ProgramsThis week we look at: IRS announces a three month Employee Retention Credit Voluntary Disclosure Program IRS provides relief from failure-to-pay penalties for 2021 and 2020 taxes for certain situations Taxpayer uses the wrong FedEx service, therefore his Tax Court petition was not filed on timeAn audio-only version of this week’s broadcast can be downloaded or streamed below:
Articles related to this week’s updates can be downloaded below:2023-12-26 Current Federal Tax Developments2023-12-2400 min
Current Federal Tax Developments2023-12-18 FinCEN BOI WeekThis week we look at: FinCEN adds more information to FAQ page, including information on PDF form Bill passes House that would give a limited extension of time for some initial BOI reports to be filed IRS releases mileage rates for 2024 Supreme Court agrees to hear estate tax valuation case to resolve split in the CircuitsAn audio-only version of this week’s broadcast can be streamed or downloaded below:
Slides and links to articles for this week’s update can be downloaded below.2023-12-18...2023-12-1700 min
Current Federal Tax Developments2023-12-11 First ERC Challenge in CourtThis week we look at: IRS sends out a batch of 20,000 ERC rejection letters Employer files suit claiming IRS ERC guidance violated the Administrative Procedures Act SCOTUS hears oral arguments in the Moore case Draft K-2/K-3 instructions are published with no major changes to the domestic filing exception for 2023An audio-only version of this week’s broadcast can be streamed or downloaded below:
A PDF with the slides and links for this week can be downloaded below:2023-12-11 Current Federal Tax Developments2023-12-1100 min
Current Federal Tax Developments2023-12-04 State Law Limited Partners and Self-Employment TaxThis week we look at: FinCEN finalizes extension of due date for initial BOI reports for entities created in 2024 Tax Court rules that a state law limited partner is not automatically covered by IRC §1402(a)(13) self-employment tax exemption OPR due diligence alert on FBAR Annual business MeF shutdown date announced IRS denies request for automatic accounting method change late election relief Tax Court finds that if date to file a Tax Court petition falls on a date that the clerk’s office is inaccessible, the taxpayer qualifies for extended fil...2023-12-0300 min
Current Federal Tax Developments2023-11-27 FinCEN Becomes Part of ERC Fraud EnforcementThis week we look at:IRS delays certain parts of expanded Form 1099-K filings added in ARPA to 2024 tax yearsFinCEN enters the ERC fraud enforcement game, publishing 10 red flags for financial institutions to use to identify suspicious transactions that may need to be reported to FinCENAn audio only version of this week’s update can be streamed or downloaded below:
Slides and links to materials for this week’s update can be downloaded below:2023-11-27 Current Federal Tax Developments2023-11-2500 min
Current Federal Tax Developments2023-11-20 FinCEN FAQ Update for BOI ReportingThis week we look at: IRS clarified FAQ on §139A and backpay for wrongfully incarcerated members of the armed services FinCEN adds to the FAQ on beneficial ownership information reportingAn audio-only version of this week’s broadcast can be streamed or downloaded below:
This week’s slides and citations can be downloaded below:2023-11-20 Current Federal Tax Developments2023-11-1900 min
Current Federal Tax Developments2023-11-06 Retirement Plan Numbers Released for 2024This week we look at: 2024 inflation adjusted retirement numbers released by the IRS MeF 1040 shutdown date announced by the IRS Trust found liable for transferee tax in failed Son-of-BOSS shelter to offset stock sale gain IRC §41 refund claim grace period extended for yet another year Tax Court refuses to expand equitable relief for missing 90-day deadline to file petitionAn audio only version of this week’s update can be downloaded or streamed below:
A copy of the slides and links to the documents can be...2023-11-0400 min
Current Federal Tax Developments2023-10-30 Boyle Decision Applies to Electronic FilingThis week we look atTaxpayers can’t rely on paid preparer as reasonable cause for late filing, even when using electronic filingIRS could assert negligence penalty (and obtain supervisory approval) after failing to obtain approval for substantial underpayment penaltyIRS makes “temporary” electronic signature program permanent by moving it into the Internal Revenue ManualAn audio only version of this week’s update can be streamed or downloaded below:
The slides and links to documents for this week’s update can be downloaded at:2023-10-30 Curren...2023-10-3000 min
Current Federal Tax Developments2023-10-23 An Offer The Actor Should Have RefusedThis week we look at PTIN renewals are now open for 2024 IRS announces program to allow for withdraw of ERC claims Actor’s estate loses in attempt to claim he had validly rolled over a non-traditional investment held in his IRA
This week’s slides and supporting document links:2023-10-23 Current Federal Tax Developments2023-10-2100 min
Current Federal Tax Developments2023-10-09 EV Credit Transfer to Dealer Guidance IssuedThis week we look at Sloppy records cost CPA the vast majority of his business deductions IRS issues warning about art deduction tax promotions aimed at high-income taxpayers IRS gives details on transfers of electrical vehicle credits to dealers beginning in 2024An audio only version of this week’s broadcast can be streamed or downloaded below:
The slides and links to the documents discussed can be downloaded via the link below:2023-10-09 Current Federal Tax Developments2023-10-0800 min
Current Federal Tax Developments2023-09-30 Limited Delay in Some CTA BOI Initial Report Filing DatesThis week we look at: IRS reduces PTIN fees substantially Wash sale rules do not apply to losses on disposition of money market funds IRS highlights new capabilities added to TaxPro accounts Employers can set up leave-based donation programs for 2023 Hawaii wildfire relief FinCEN grants 60 additional days for entities created in 2024 to file initial reportsAn audio-only version of this week’s broadcast can be streamed or downloaded below:
A PDF of the slides and links to supporting materials can be downloaded below:2023-1...2023-09-3000 min
Current Federal Tax Developments2023-09-25 FinCEN Issues Guide for Small Business CTA BOI ReportingThis week we look at: FinCEN provides guide to small businesses for beneficial ownership reporting under the Corporate Transparency Act Taxpayer cannot rely on the mailbox rule to prove timely mailing/filing of tax return, as §7502 is the sole way of proving timely postmark and get presumption of delivery Impact of receipt of a CP2100/2100A notice on backup withholdingThe audio only version of this week’s broadcast can be streamed or downloaded below:
A PDF with the slides and links to articles can be downloaded below:...2023-09-2300 min
Current Federal Tax Developments2023-09-18 Halt in ERC Claim Processing for New ClaimsThis week we look at: Just having a CPA prepare a taxpayer’s return does mean the taxpayer will get reasonable cause relief for assessments IRS announces halt to processing of new ERC claims until after 2023, will slow processing of claims currently in progressAn audio only broadcast of this week’s update can be streamed or downloaded below:
A PDF of this week’s slides and links to articles on the developments.2023-09-18 Current Federal Tax Developments2023-09-1600 min
Current Federal Tax Developments2023-09-11 Better Late Than Never Section 174 Guidance ArrivesThis week we look at: IRS make last minute change to K-2/K-3 FAQ for 2022 returns Preliminary guidance for §174 changes made in TCJA that took effect in 2022 issued by the IRSThe audio version of this week’s broadcast can be streamed or downloaded below.
You can download the slides and links to the documents and articles below.2023-09-11 Current Federal Tax Developments2023-09-1100 min
Current Federal Tax Developments2023-09-05 Electronic Filing of Information Return Mandate IssuesThis week we look at: HHS sends letter to DEA recommending that marijuana be reclassified as a Schedule III drug General guidance issued determining tax status of 2023 state payments - and IRS asks for comments prior to giving additional guidance IRS clarifies limits of 2007 CCA on ESBTs and NOLs News release on electronic filing of Form 8300
The slides and this week’s article links can be downloaded below:2023-09-05 Current Federal Tax Developments2023-09-0200 min
Current Federal Tax Developments2023-08-28 Week of IRS Delaying RequirementsThis week we look at: Proposed regulations issued for digital asset broker reporting on Form 1099-DA IRS delays requirement for high income employees to make employer plan catch-up contribution to designated Roth accounts until plan years beginning after December 31, 2025 2024 health care premium tax credit percentages published by the IRSAn audio only version of this week’s broadcast can be streamed or downloaded below:
Links to the articles for this week’s update and the slides can be downloaded below.2023-08-28 Current Federal Tax Developments2023-08-2800 min
Current Federal Tax Developments2023-08-21 Renting The Owners' Homes To Their Business Didn't Work As Well As ExpectedThis week we look at:Limited relief likely coming for beneficial ownership reportingIRS being challenged in an attempt to treat state law limited partners as receiving SE incomeRent your home to your business for 13 days each year plan mainly failedAdvance memo states IRS objection to a marketed trust tax avoidance planIRS memo explains credit unions can only claim COVID ERC on 2021 wagesAn audio only version of this week’s update can be downloaded or streamed below:
A copy of the sl...2023-08-2100 min
Current Federal Tax Developments2023-08-14 IRS Issues Warning for Certain ESOP ProgramsThis week we look at:Deduction for non-qualified deferred compensation not accelerated for the seller when the liability is transferred to the buyer of a business Tax professionals and taxpayers warned about issues with certain employee stock ownership plan (ESOP) arrangementsReduction of non-recourse debt amount was added to sales proceeds, not a cancellation of debt so no §108 relief was availableAn audio only version of this week’s broadcast can be streamed or downloaded below.
A PDF of the slides and links to articles for each update can be...2023-08-1300 min
Current Federal Tax Developments2023-08-07 IRS Finally Tells Us Their Position on Staking RewardsThis week we look at: IRS rules cryptocurrency staking rewards are taxable when taxpayer obtains dominion and control Interim guidance issued for home energy audit tax credit under IRC §25C added by IRA 2022 Proposed regulations issued to add monetized installment sales to listed transactionsAn audio only version of this week’s broadcast can be streamed or downloaded below:
The slides for this week’s broadcast and links to articles can be downloaded below:2023-08-07 Current Federal Tax Developments2023-08-0600 min
Current Federal Tax Developments2023-07-31 The ERC Hearing Before Congress Left for the August RecessThis week we look at:Oversight Subcommittee of House Ways & Means Committee holds a hearing on ERC issues, discusses potential amnesty programIRS ending most announced revenue officer visitsTaxpayer finds out that there may very well be a tax consequence when you borrow against your life insurance policy and then let the policy lapseAn audio only version of this week’s broadcast can be streamed or downloaded below:
Copies of slide and links to articles on the topics and certain other items can be downloaded below:2023-07-3100 min
Current Federal Tax Developments2023-07-24 IRS Makes Clear Its Position on Extended Supply Chain ERC ClaimsThis week we look at: IRS memo makes it clear the agency is very skeptical about extended supply chain ERC claims Third Circuit rules that equitable relief is available for failure to file Tax Court petition in 90 day period for a deficiency IRS asked by Tax Court to justify suspense account method for losses deducted in excess of basis in closed years Taxpayers had to pay tax on funds taken from IRA/pension funds that were paid to fraudsterAn audio only version of this week’s broadcast can be...2023-07-2400 min
Current Federal Tax Developments2023-07-17 IRS Extends RMD Relief by One YearThis week we look at: IRS extends SECURE Act inherited IRA RMD relief for one additional year, adds special rollover rule for those born in 1951 due to SECURE 2.0 Act changes IRS grants relief to victims of Vermont flooding. Failure to attach simple election leads to requesting (and paying for) 11 separate private letter rulingsAn audio only version of this week’s podcast can be streamed or downloaded below:
Slides and links to this week’s write-ups can be downloaded below:2023-07-17 Current Federal Tax Developments2023-07-1700 min
Current Federal Tax Developments2023-07-10 Research Credit BluesThis week we look at:S corporation loses on research credit claim and gets hit with penalties - risks of a credit studyExempt organization status denied for organization formed to raise funds for one person’s medical billsDiscussion of tax research hierarchy in this short weekAn audio only version of this week’s broadcast can be downloaded or streamed below:
A copy of the slides and links can be downloaded below:2023-07-10 Current Federal Tax Developments2023-07-1000 min
Current Federal Tax Developments2023-07-03 Supreme Court, Protective Claims and 965 Transition TaxThis week we look at: Supreme Court takes on §965 transition tax case for upcoming term: what do we do to protect our clients?The IRS releases draft versions of key 2023 partnership income tax returnsFirefighter’s sexual harassment complaint settlement was not excludable from incomeAn audio only version of this week’s update can be downloaded or streamed below:
A PDF of this week’s slides and links can be downloaded via the link below:2023-07-03 Current Federal Tax Developments2023-07-0300 min