The United States Tax Court’s recent memorandum opinion in Kramarenko v. Commissioner, T.C. Memo. 2025-61, provides a crucial analysis for tax professionals concerning the interpretation and application of tax treaty provisions, particularly those related to exemptions for students, trainees, and researchers. This case reinforces the distinction between taxable compensation for services and tax-exempt grants, emphasizing the "quid pro quo" doctrine as a cornerstone of the analysis.

As tax professionals, staying abreast of the latest guidance from the Internal Revenue Service (IRS) is paramount to ensuring compliance and providing accurate advice to our clients. Revenue Procedure 2025-23, effective for Forms 3115 filed on or after June 9, 2025, for a year of change ending on or after October 31, 2024, provides a comprehensive list of automatic changes in accounting methods. This Revenue Procedure clarifies and modifies previous guidance, specifically Rev. Proc. 2015-13, 2015-5 I.R.B. 419, and its subsequent modifications. It is an essential resource for taxpayers seeking to change their accounting methods without obtaining advance consent from the Commissioner.

The recent Supreme Court decision in Catholic Charities Bureau, Inc. v. Wisconsin Labor and Industry Review Commission offers critical insights for tax professionals advising religious organizations on unemployment compensation tax exemptions. This ruling underscores the profound interplay between First Amendment principles and state tax laws, particularly when such laws differentiate among religious practices.

The Office of Tax Appeals (OTA) recently issued an opinion in In the Matter of the Appeal of: Q. Tran and R. Medina, OTA Case No. 21088364, addressing critical questions of California residency for the 2007, 2008, and 2009 tax years. This case provides valuable insights into the rigorous standards taxpayers must meet to demonstrate a change in domicile and residency for California tax purposes.

Tax professionals frequently encounter complex scenarios involving intra-entity transfers and debt cancellations. A recent Ninth Circuit decision, Kelly v. Commissioner, No. 23-70040 (9th Cir. 2025), provides critical clarification on the distinct legal standards for claiming a nonbusiness bad-debt deduction under 26 U.S.C. § 166 and recognizing cancellation-of-debt (COD) income under 26 U.S.C. § 61(a)(11) and § 108. This opinion underscores the principle that a debt’s discharge does not automatically render it "wholly worthless" for deduction purposes, rejecting a taxpayer’s attempt to create a simultaneous deduction upon debt cancellation.

As tax professionals, staying abreast of changes in federal payment mechanisms is crucial, especially as the U.S. Department of the Treasury (Treasury) moves towards a fully digitized payment landscape. This article details a significant Request for Information (RFI) issued by the Treasury, inviting public input on the implementation of Executive Order (E.O.) 14247, "Modernizing Payments To and From America’s Bank Account". Understanding this RFI is vital for advising clients, particularly given its direct implications for receiving federal disbursements such as tax refunds.

As tax professionals, understanding the nuances of accuracy-related penalties under Internal Revenue Code (I.R.C.) Section 6662 is paramount. The recent U.S. Tax Court Memorandum Opinion in Ataya v. Commissioner, T.C. Memo. 2025-55, provides a compelling case study illustrating the stringent requirements for taxpayers to demonstrate reasonable cause and good faith, particularly concerning recordkeeping and reliance on tax preparers. This analysis will delve into the factual background, the legal framework applied by the Court, and its ultimate conclusions.

As tax professionals, assisting clients with tax collection issues is a critical part of our practice. A recent Tax Court Memorandum decision, Palli v. Commissioner, T.C. Memo. 2025-54, offers valuable insights into the Internal Revenue Service’s Collection Due Process (CDP) framework, particularly concerning Offers in Compromise (OICs) based on doubt as to collectibility. This case highlights the importance of timely communication, providing comprehensive and updated financial information, and understanding the IRS’s procedural guidelines (including the Internal Revenue Manual (IRM)) as interpreted by the Tax Court.

In a recent Memorandum Opinion, the U.S. Tax Court addressed the valuation of a conservation easement donation by Beaverdam Creek Holdings, LLC ("Beaverdam"). The case, Beaverdam Creek Holdings, LLC v. Commissioner, Docket No. 12362-21, involved a dispute over a noncash charitable contribution deduction claimed for the donation of an easement over 85 acres of property in Oglethorpe County, Georgia. The court’s analysis offers significant insights into valuation methodologies, burden of proof in deduction cases, qualified appraisal requirements, and the application of accuracy-related penalties.

Tax professionals advising corporate clients must grapple with the complexities introduced by the Corporate Alternative Minimum Tax (CAMT), enacted by the Inflation Reduction Act of 2022. The CAMT, imposed under Internal Revenue Code (Code) § 55, applies to "applicable corporations" and is based on their "adjusted financial statement income" (AFSI) for taxable years beginning after December 31, 2022. The determination of "applicable corporation" status and the calculation of AFSI have been areas of significant focus for both taxpayers and the Internal Revenue Service (IRS). Notice 2025-27 provides further interim guidance on these matters, including an optional simplified method for determining applicable corporation status and critical relief from certain additions to tax under § 6655 related to CAMT liability.

As tax professionals, navigating the complexities of international information reporting can be challenging, both for us and our clients. A recent case in the Northern District of California, Jiaxing Huang v. United States of America, Case No. 24-cv-06298-RS, offers insights into how courts are addressing penalties related to foreign gift reporting, specifically Form 3520, and the defenses available to taxpayers. This article provides an overview of the case’s facts, the taxpayer’s claims, and the court’s analysis on the government’s motion to dismiss.

A critical question for tax practitioners advising nonresident clients arises when those clients sell stock in a Massachusetts-based entity they were involved with, particularly if they were also employees. The Massachusetts Appeals Court recently affirmed the Appellate Tax Board’s decision in Craig H. & Natalia I. Welch v. Commissioner of Revenue, concluding that the gain from a founder’s sale of stock in his former employer was Massachusetts source income. The appellants, Craig H. & Natalia I. Welch, are seeking further appellate review from the Supreme Judicial Court of Massachusetts. This case presents a significant issue of first impression impacting countless Massachusetts entrepreneurs and key employees.

An order was issued on May 29, 2025 from the United States Court of Appeals for the Federal Circuit in the consolidated cases under the lead title V.O.S. SELECTIONS, INC. v. TRUMP. This order is noted as nonprecedential.

The order addresses appeals from the United States Court of International Trade. In the underlying proceedings, the Court of International Trade had entered judgments against the United States. These judgments included permanently enjoining certain Executive Orders imposing various tariffs.

The United States Court of International Trade (USCIT) recently issued a significant opinion concerning the scope of the President’s authority to impose tariffs under the International Emergency Economic Powers Act (IEEPA). This decision, arising from two consolidated cases (V.O.S. Selections, Inc. v. United States and The State of Oregon v. United States), directly impacts businesses engaged in international trade and highlights crucial limitations on executive power that tax professionals should understand for advising clients involved in import activities. The court ultimately granted the Plaintiffs’ Motions for Summary Judgment, declaring the challenged tariffs unlawful and vacating and permanently enjoining their operation.

The recent U.S. Tax Court memorandum opinion in Soroban Capital Partners LP v. Commissioner, T.C. Memo. 2025-52, provides further application of the functional analysis test previously established in Soroban Capital Partners LP v. Commissioner, 161 T.C. 310 (2023) and applied in cases like Denham Capital Management LP v. Commissioner, T.C. Memo. 2024-114. This case underscores the critical need for tax practitioners to look beyond state law labels when determining whether a partner’s distributive share of income is subject to self-employment tax under Section 1402(a)(13).

The recent decision by the New York Tax Appeals Tribunal in Matter of Edward A. and Doris Zelinsky (DTANOS. 830517 AND 830681, May 9, 2025) provides crucial guidance for CPAs advising nonresident clients employed by New York businesses, particularly in the wake of the increased remote work environment. This article delves into the factual background, the petitioners’ arguments, the legal framework applied, and the Tribunal’s reasoning, highlighting the continued relevance and application of New York’s "convenience of the employer" rule.

Practitioners specializing in international taxation and transfer pricing are keenly aware of the complexities inherent in intercompany transactions, particularly those involving high-value intangible property. The United States Tax Court’s decision in Facebook, Inc. & Subsidiaries v. Commissioner, 164 T.C. No. 9 (2025), offers crucial insights into the application of Section 482 and the temporary cost sharing regulations (Temp. Treas. Reg. § 1.482-7T) to such arrangements. This article delves into the facts, the taxpayer’s challenges, the Court’s legal analysis, the application of the law to the specifics of the case, and the resulting conclusions.

On May 20, 2025, the Senate unanimously passed S.129, titled the "No Tax on Tips Act". This Act proposes amendments to the Internal Revenue Code of 1986 with the stated purpose of eliminating the application of the income tax on qualified tips through a deduction allowed to all individual taxpayers, and for other purposes. The bill also includes provisions related to the employer credit for a portion of social security taxes paid with respect to employee tips.

There are similar, but not identical, tip provisions in The One, Big, Beautiful Bill under consideration in the House of Representatives.

In Jordan John O’Neill v. Commissioner of Internal Revenue, T.C. Memo. 2025-49, the United States Tax Court addressed crucial jurisdictional questions stemming from a taxpayer’s challenge to Notices of Deficiency and the timeliness of his petition. The case highlights the technical requirements for both the Internal Revenue Service (IRS) and taxpayers in deficiency proceedings before the Tax Court.

A recent Memorandum and Order from the United States District Court for the District of Rhode Island, The Estate of Vincenzo Sandonato v. United States of America, C.A. No. 23-304-JJM-AEM, offers valuable insights for a tax practice regarding the "reasonable cause" exception to the failure to file penalty under I.R.C. § 6651(a)(1). The case underscores the importance of documented advice and the factual nature of the reasonable reliance defense.