The Internal Revenue Service (IRS) and the Treasury Department have issued final regulations (T.D. 10028) under section 6011 of the Internal Revenue Code (Code), aimed at curbing tax avoidance through certain partnership related-party basis adjustment transactions. These regulations, which add § 1.6011-18 to the Income Tax Regulations, identify these transactions as “transactions of interest,” a type of reportable transaction. This article provides a comprehensive overview of these final regulations, including their effective date, the specific sections of the Code they interpret or impact, and the relevant authorities cited.

The Internal Revenue Service (IRS) has released proposed regulations providing guidance on the qualified commercial clean vehicle credit under Section 45W of the Internal Revenue Code (IRC). This credit, enacted as part of the Inflation Reduction Act of 2022 (IRA), offers a significant tax benefit to businesses investing in clean transportation. These proposed regulations aim to clarify several aspects of the credit, including the definition of qualified vehicles, the calculation of the credit amount, and reporting requirements.

The SECURE 2.0 Act, enacted on December 29, 2022, brought about several key modifications to the rules governing retirement plans. Among these, Section 101 of the Act introduced Section 414A to the Internal Revenue Code (Code), which mandates automatic enrollment for specific retirement plans. The proposed regulations, issued by the IRS and the Department of the Treasury, interpret and implement these statutory changes. Additionally, the Act included provisions related to the consolidation of notices, which impact how plan sponsors communicate with participants.

This Joint Committee on Taxation report (JCX-1-25) lists various federal tax provisions that have expired or are scheduled to expire between 2024 and 2034\. The provisions are categorized by the year in which they expire.

This Tax Court case, Ishveen K. Chopra v. Commissioner, T.C. Memo. 2025-2, serves as a stark reminder of the consequences of not only failing to properly substantiate deductions, but also engaging in outright fraud. The Court upheld the IRS’s determination of a $30,520 deficiency and a civil fraud penalty of $22,890. This case provides valuable insights into the standards of proof and the “badges of fraud” that tax professionals should be aware of.

A US District Court court granted a preliminary injunction and stay in the case of Smith, et al. v. US Department of the Treasury, Case No. 6:24-cv-00336, US District Court ED Texas, finding that the Corporate Transparency Act (CTA) and its implementing rule are likely unconstitutional. The court determined that the plaintiffs, Samantha Smith and Robert Means, demonstrated a substantial likelihood of success on the merits, a substantial risk of irreparable harm, and that the balance of equities and public interest supported preliminary relief.

Revenue Ruling 2025-3 and Revenue Procedure 2025-10 provide updated guidance regarding Section 530 of the Revenue Act of 1978, which addresses controversies involving whether individuals are employees for purposes of employment taxes.

The National Taxpayer Advocate (NTA) has released the 2024 Annual Report to Congress, along with the 2025 Purple Book, a compilation of legislative recommendations. These documents highlight critical issues facing taxpayers and propose solutions that could significantly impact tax practice. This article will delve into the key findings of the report and the legislative recommendations, offering insights relevant to CPAs in tax practice.

BankUnited, Inc. v. United States of America, US District Court Southern District of Florida, Case no. 1:23-cv-20379-KMM, revolves around a tax refund dispute initiated by BankUnited, Inc. (BUI) against the United States of America. The dispute arose from BUI’s 2009 acquisition of a failed bank and the subsequent tax treatment of the acquired assets.

The Seventh Circuit Court of Appeals decided the case of Bachner v. Commissioner, No. 24-1420, on January 7, 2025, which provides a clear illustration of how the IRS and courts handle cases of fraudulent tax returns and the assessment of penalties. This case particularly highlights the complexities surrounding the calculation of underpayments when taxpayers fraudulently overstate their withholdings.

The “Employer Reporting Improvement Act” (H.R. 3801\) makes several amendments to the Internal Revenue Code of 1986, primarily concerning employer reporting requirements related to health insurance coverage. Here’s a breakdown of the key provisions and their effective dates:

The IRS has published Revenue Procedure 2024-44[^1], an update on adequate disclosure on tax returns that are filed for purposes of reducing penalties that may be imposed on a taxpayer under IRC §6662(d) or on a tax preparer under IRC §6694. The IRS normally releases these updates annually.

Matthew Hutcheson at the very end of 2024 and very beginning of 2025 received both good news and bad news. Mr. Hutcheson, who had been convicted of wire fraud in 2013 and sentenced to 17 years in prison had his remaining sentence commuted by President Biden as part of his end of term pardons and sentence commutations on December 12, 2024. But three days into 2025, Mr. Hutcheson received less upbeat news, as the Tax Court found he owed taxes on the amounts he embezzled that led to those 2013 convictions in the case of Hutcheson v. Commissioner.

In the case of Capitol Places II Owner, LLC, et al v. Commissioner, the Tax Court denied a charitable contribution deduction for a facade easement, finding the building in question did meet the definition of a certified historic structure under IRC §170(h)(4).

IRS Action on Decision (AOD) 2024-01[^1] addresses the validity of listing notices issued without following the Administrative Procedure Act (APA) notice-and-comment rulemaking procedures, specifically after the American Jobs Creation Act of 2004 (AJCA).

The Department of Justice has filed an emergency request for the US Supreme Court to remove the injunction against enforcement of the Corporate Transparency Act the Fifth Circuit had put back in place on December 26, 2024.

The Department of Justice has filed to ask the Supreme Court to take action to remove the stay recently reimposed by the Fifth Circuit Court of Appeals of the enforcement of the Corporate Transparency Act.

DOJ’s Request for Supreme Court Action to Remove Stay on Enforcement of CTA

To close out 2024, the IRS released Revenue Procedure 2025-7 providing temporary relief provisions for allowing taxpayers to specifically identify specific blocks of digital assets sold from a brokerage account in 2025. This relief is in addition to special rules adopted earlier this year in Revenue Procedure 2024-28 for allocating unallocated basis as taxpayers transition to the provisions of Reg. §1.1012-1(j).

FinCEN updated their website on December 27, 2024 to reflect the latest reversal of direction by the courts in the BOI deadline matter, noting that, for now, there is a stay of the deadline to file BOI reports in place and that voluntary submissions will continue to be accepted during the period the stay is in effect.

On December 26, 2024, an order was issued vacating a previous stay that had been granted regarding the enforcement of the Corporate Transparency Act (CTA) and its corresponding Reporting Rule. The stay had been granted by a motions panel of the Fifth Circuit Court of Appeals on December 23, 2024, but was vacated by the merits panel of the same court. The order vacating the stay was made to “preserve the constitutional status quo while the merits panel considers the parties’ weighty substantive arguments”