The Chief Counsel Advice (CCA 202504014) memorandum discusses the examination of a tax-exempt private foundation (the Foundation) and its financial dealings with business entities owned and operated by its foundation manager.

The US Supreme Court has reversed the decision of the Fifth Circuit Court of Appeals Merits Panel and again removed the injunction issued by the US District Court for the Eastern District of Texas against enforcement of the beneficial ownership reports under the Corporate Transparency Act (McHenry v. Texas Top Cop Shop (originally Texas Top Cop Shop, Inc. v. Garland), Application for Stay, US Supreme Court, January 23, 2025). As of the time this is being written FinCEN has not yet posted information about the new due date for reports originally due while the enforcement was on hold.

The case of Franklin v. Commissioner, TC Memo 2025-8,  involves a dispute between Ana M. Franklin (the petitioner) and the Commissioner of Internal Revenue (the respondent) regarding deficiencies in the petitioner’s federal income tax for 2015 and 2018. The court consolidated the cases for trial, briefing, and opinion.

This case, Seabrook Property, LLC v. Commissioner, involves a dispute over a noncash charitable contribution deduction claimed by Seabrook Property, LLC (Seabrook) for a conservation easement it granted on approximately 622 acres of land in Liberty County, Georgia. The Commissioner of Internal Revenue disallowed the deduction in full, also determining that Seabrook was subject to accuracy-related and reportable transaction penalties.

The Tax Cuts and Jobs Act (TCJA) of 2017 included many provisions that are scheduled to expire, mostly at the end of 2025. The Congressional Research Service (CRS) report from January 17, 2025, details these expiring provisions and provides estimates of the revenue effects of extending them. According to the Joint Committee on Taxation (JCT), extending the expiring individual income tax provisions would reduce federal tax collections by $3.3 trillion over the 10-year budget window from FY2025-FY2034. Extending the higher estate tax exemptions would cost $167 billion, and extending the business provisions would cost $551 billion. Overall, the JCT forecasts that extending these provisions would cost $4 trillion. In most years, the revenue loss would be between 1.2% and 1.4% of gross domestic product (GDP)

The Inflation Reduction Act of 2022 (IRA) contained significant changes to both the Energy Efficient Home Improvement Credit under Internal Revenue Code (IRC) Section 25C and the Residential Clean Energy Property Credit under IRC Section 25D. These updated FAQs provide details on the IRA’s changes to these credits, revised as of January 17, 2025.  One key update is the addition of information regarding the PIN reporting requirements for claiming these credits for assets placed in service on or after January 1, 2025.

In Debra Reed and Timothy Reed v. Commissioner of Internal Revenue, T.C. Memo. 2025-4, the Tax Court addressed whether it had the authority to review a petition filed outside the 30-day deadline for challenging a notice of determination in a collection due process (CDP) case. The court ultimately granted the Commissioner’s motion to dismiss, finding that the taxpayers had failed to demonstrate they were entitled to equitable tolling of the filing deadline. This case serves as an important reminder of the strict deadlines associated with Tax Court filings and the high bar for establishing equitable tolling.

The IRS recently issued Revenue Ruling 2025-4 to clarify the federal income and employment tax treatment of contributions and benefits paid under state-mandated Paid Family and Medical Leave (PFML) programs. This ruling addresses the tax implications for both employers and employees, especially in states like State X which is used as a model throughout the ruling. Let’s break down each aspect of this ruling in detail.

Notice 2025-9 provides updated safe harbors for calculating the incremental cost and retail price equivalent (RPE) of qualified commercial clean vehicles for the purposes of the section 45W credit.

Announcement 2025-6 describes a pilot program testing changes to the Fast Track Settlement (FTS) programs currently available to taxpayers under examination in the Large Business and International (LB&I), Small Business/Self-Employed (SB/SE), and Tax Exempt/Government Entities (TE/GE) operating divisions. FTS enables taxpayers with unagreed issues in at least one open tax year under examination to work with the IRS and the Independent Office of Appeals to resolve disputed factual and legal issues while the case is still under the jurisdiction of the Examination Division. The pilot program also includes changes to Post Appeals Mediation (PAM) procedures and introduces a “Last Chance FTS” pilot program for SB/SE taxpayers.

The IRS and the Coalition of Scam and Scheme Threats (CASST) have announced changes for the 2025 filing season to protect taxpayers from scams and schemes.

The IRS has issued final regulations (TD 10030) that significantly impact the resolution of Federal tax controversies by the Independent Office of Appeals (Appeals). These regulations, which implement section 7803(e) of the Internal Revenue Code (Code) as enacted by the Taxpayer First Act of 2019 (TFA), provide essential guidance for tax professionals.

The Internal Revenue Service (IRS) has issued final regulations (TD 10029) that identify certain micro-captive transactions as listed transactions and transactions of interest, both of which are types of reportable transactions. These regulations, which are effective January 14, 2025, require material advisors and certain participants to file disclosures with the IRS, with penalties for non-compliance. This article provides an overview of these regulations and their implications for CPAs and their clients.

The Internal Revenue Service (IRS) has announced tax relief for individuals and businesses in southern California affected by the wildfires and straight-line winds that began on January 7, 2025. This relief postpones various tax filing and payment deadlines to October 15, 2025.

The Internal Revenue Service (IRS) has released proposed regulations (REG-101268-24) providing guidance on retirement plan catch-up contributions, reflecting changes introduced by the SECURE 2.0 Act of 2022. These regulations, which amend 26 CFR Part 1, primarily affect retirement plans under IRC Sections 401(k), 403(b), and 414(v). The proposed rules introduce new requirements for Roth catch-up contributions and changes to applicable dollar limits. This article will analyze these proposed regulations, citing relevant legal and regulatory authorities to provide a comprehensive understanding.

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.