The Large Business and International (LB&I) Division has announced significant modifications to its examination process, outlined in a recent memorandum effective August 1, 2025. These changes are intended to foster more efficient and effective examinations, enhance taxpayer service, and promote collaborative issue resolution. This article will delve into the procedural updates concerning the elimination of the Acknowledgment of Facts (AOF) Information Document Request (IDR), the updated Fast Track Settlements (FTS) pilot program, and clarifications regarding the applicability of Accelerated Issue Resolution (AIR) to Large Corporate Compliance (LCC) cases.

Staying abreast of changes to the Affordable Care Act’s (ACA) Employer Shared Responsibility Provisions (ESRP) under Internal Revenue Code (IRC) Section 4980H is crucial for advising applicable large employers (ALEs). The Internal Revenue Service (IRS) recently released Rev. Proc. 2025-26, providing the indexing adjustments for the upcoming calendar year 2026. This article will detail the foundational elements of the ESRP, outline the recent adjustments, and discuss other key administrative considerations.

The recent decision in Carole Nicholson v. United States of America, USDC ND FL, Case No. 3:24-cv-00603, serves as a reminder for tax professionals regarding the strict procedural requirements for tax refund claims. This case underscores the jurisdictional prerequisites that must be satisfied before a federal court can hear a taxpayer’s suit against the Internal Revenue Service (IRS), particularly concerning the proper forms and timeliness of administrative claims.

In the realm of tax practice, the substantiation of deductions often proves to be a contentious area, particularly with noncash charitable contributions. The recent Tax Court Summary Opinion in John Henry Besaw v. Commissioner, T.C. Summary Opinion 2025-7, Docket No. 19222-22S (July 21, 2025), provides a stark reminder of the meticulous record-keeping required to preserve these deductions. This case underscores the importance of adhering strictly to statutory and regulatory substantiation rules, even when the underlying charitable intent is not disputed.

Tax professionals must remain apprised of the annual adjustments to critical provisions governing the Affordable Care Act (ACA), particularly those affecting the premium tax credit (PTC) under Internal Revenue Code (Code) §36B and the affordability of employer-sponsored health coverage. Rev. Proc. 2025-25, 2025-32 IRB 1, issued by the Internal Revenue Service (IRS) and the Department of the Treasury, provides these essential indexing adjustments for taxable years and plan years beginning in calendar year 2026. This revenue procedure supplements Rev. Proc. 2014-37, 2014-2 C.B. 363, which outlined the original methodology for these adjustments.

The United States Court of Appeals for the Fifth Circuit recently affirmed the Tax Court’s decision disallowing tax deductions for insurance premium payments made by Dr. Bernard T. Swift’s medical practice to his captive insurance companies and upholding associated penalties. This case, Bernard T. Swift, Jr.; Kathy L. Swift v. Commissioner of Internal Revenue, No. 24-60270, provides crucial insights into the criteria for genuine insurance arrangements and the application of accuracy-related penalties in the context of micro-captive transactions.

Revenue Ruling 2025-15 provides crucial clarification for plan administrators and tax professionals regarding federal income tax withholding and reporting obligations when retirement plan distribution checks remain uncashed and subsequent checks are issued. This analysis delves into the facts presented in the ruling, the Internal Revenue Service’s (IRS) legal interpretation, its application to the specific scenario, and the definitive rules established.

Tax professionals are continually challenged by the complexities surrounding conservation easement valuations, a recurring point of contention with the Internal Revenue Service. The recent Tax Court case, Veribest Vesta, LLC v. Commissioner of Internal Revenue, Docket No. 9158-23, provides valuable insights into the Court’s scrutiny of claimed deductions for such easements, particularly when valuations appear overly optimistic or lack sufficient market support. This article will delve into the facts of this case, the taxpayer’s request for relief, the legal analysis, the application of law to the facts, and the Court’s ultimate conclusions.

As tax professionals, we frequently encounter statutory deadlines that dictate our clients’ rights and our obligations. One area of particular interest, especially following a significant Supreme Court ruling, is the doctrine of equitable tolling as it applies to the Tax Court’s filing deadlines. The recent oral findings of fact and opinion in Boechler, P.C. v. Commissioner of Internal Revenue, Docket No. 18578-17L (Bench Opinion June 12, 2025), provides a practical application of this doctrine following its remand from the United States Court of Appeals for the Eighth Circuit. This article will delve into the specifics of this case, outlining the factual background, the taxpayer’s plea for relief, the court’s legal analysis of equitable tolling, and its ultimate conclusions.

The United States Tax Court’s decision in Estate of Billy S. Rowland, Deceased, James A. Park, Executor v. Commissioner of Internal Revenue, T.C. Memo. 2025-76, provides critical insights for tax professionals concerning the deceased spousal unused exclusion (DSUE) amount and the stringent requirements for electing portability. This case underscores the importance of strict compliance with filing deadlines and return preparation standards, even when attempting to utilize administrative safe harbors.

The recent decision in Rock Cliff Reserve, LLC v. Commissioner, T.C. Memo. 2025-73, offers crucial insights for tax professionals navigating the complexities of conservation easement deductions and related penalties. This memorandum opinion addresses consolidated cases involving four partnerships—Rock Cliff Reserve, LLC (Rock Cliff PropertyCo), Jack’s Creek Reserve, LLC (Jack’s Creek PropertyCo), East Village Reserve, LLC (East Village PropertyCo), and Baker’s Farm Nature Reserve, LLC (Baker’s Farm PropertyCo), collectively referred to as the PropertyCos. Five Rivers Conservation Group, LLC (Five Rivers), served as the tax matters partner for each. The case scrutinizes charitable contribution deductions claimed for conservation easements, totaling over $62 million, along with "Other Deductions" claimed in Walton County, Georgia, for the 2015 tax year.

Tax professionals who advise tax-exempt organizations are aware of the stringent rules governing political activity, particularly for entities described under Internal Revenue Code (IRC) Section 501(c)(3). A significant legal development is currently under consideration by the United States District Court for the Eastern District of Texas: a proposed consent judgment in the case of National Religious Broadcasters, et al. v. Billy Long, et al., which addresses the interpretation of the "Johnson Amendment" as it applies to churches. This proposed agreement, while not yet binding, offers crucial insights into the ongoing dialogue surrounding religious organizations' political speech and their tax-exempt status.

For experienced tax professionals, understanding the mechanisms for tax relief during unforeseen events is paramount. Internal Revenue Code (IRC) Section 7508A currently provides the Secretary of the Treasury with broad authority to postpone certain tax-related deadlines due to specific types of disasters and actions. However, a recently passed bill, the "Filing Relief for Natural Disasters Act" (H.R. 517), passed by both the House and the Senate, aims to significantly expand the scope and duration of this relief. This article details the existing provisions of Section 7508A and illuminates the key modifications this bill would introduce if enacted.  The bill was awaiting the President’s signature at the time this article was written.

Tax professionals understand that jurisdiction is a foundational element for any case brought before the United States Tax Court. As a court of limited jurisdiction, the Tax Court may only exercise authority granted by Congress. A recent memorandum opinion, Donna Davis v. Commissioner, T.C. Memo. 2025-72, offers a critical reminder of the stringent requirements for establishing jurisdiction, particularly concerning the validity of a Notice of Deficiency and the timely filing of a petition. This case underscores the importance of adherence to procedural rules, even in the face of sympathetic circumstances.

For tax professionals navigating complex compensation and wealth transfer arrangements, the Sixth Circuit’s recent decision in Peter E. McGowan; Michele L. McGowan; Peter E. McGowan DDS, Inc. v. United States of America, No. 24-3228 (July 9, 2025), offers crucial insights into the application of split-dollar life insurance regulations and the deductibility of related employer contributions. This case affirms the district court’s award of summary judgment to the government, largely upholding the IRS’s assessments against both Dr. Peter E. McGowan and his dental practice, Peter E. McGowan DDS, Inc. (the "Company").

The United States Tax Court’s recent memorandum opinion in Arden Row Assets, LLC v. Commissioner, T.C. Memo. 2025-71, offers critical insights for tax professionals navigating settlement discussions, particularly in the context of syndicated conservation easement transactions and the Bipartisan Budget Act of 2015 (BBA) partnership audit rules. This case underscores fundamental principles of contract law applied to tax settlement agreements, emphasizing the importance of clear mutual assent, adherence to prescribed acceptance methods, and proper authority under the BBA.

The recent Tax Court Memorandum in Remus Beleiu and Naomi J. Beleiu v. Commissioner of Internal Revenue, T.C. Memo. 2025-70, offers crucial insights for tax professionals concerning the imposition of civil fraud penalties under Internal Revenue Code (I.R.C.) Section 6663(a). This case highlights the rigorous standard applied by the Commissioner and the Tax Court in establishing fraudulent intent, particularly when a taxpayer possesses a strong financial and accounting background.

The recent Tax Court decision in Moxon Corporation v. Commissioner, 165 T.C. No. 2 (Filed July 2, 2025), provides critical insights for tax professionals concerning the assessment and collectibility of partnership-level penalties, particularly when underlying tax deficiencies are abated due to procedural errors. This case clarifies the distinct treatment of partnership-level penalties under deficiency procedures and the calculation of "underpayment" for penalty purposes, even in the absence of a collectible tax liability.

In a significant decision for tax professionals navigating Bipartisan Budget Act (BBA) partnership audit procedures, the United States Tax Court in JM Assets, LP v. Commissioner, 165 T.C. No. 1 (2025), delivered a ruling that clarifies the statute of limitations for final partnership adjustments, particularly when a partnership requests modification of an imputed underpayment. This opinion, penned by Judge Buch, underscores the judiciary’s role in ensuring administrative regulations adhere strictly to statutory text, drawing on recent Supreme Court precedent.

As Certified Public Accountants specializing in tax and Enrolled Agents (EA), our role extends beyond mere preparation of returns; it encompasses a rigorous adherence to professional standards set forth by the Internal Revenue Service (IRS). A critical area demanding our expertise and diligence is the Report of Foreign Bank and Financial Accounts (FBAR), FinCEN Report 114. While not a tax return itself, the FBAR is inextricably linked to U.S. tax compliance and is a significant focus of the IRS Office of Professional Responsibility (OPR). This article delves into the FBAR reporting requirements and the specific obligations imposed on practitioners by Circular 230, which governs practice before the IRS as outlined in “Tax Practice Obligations and the Report of Foreign Bank and Financial Accounts,” Alerts from Office of Professional Responsibility, Issue Number: 2025-10.