Keeping CPAs Up to Date on Tax Matters
A site devoted to articles on current developments in federal taxes geared toward CPAs in tax practice.
This week we look at:
Corporate Capacity and State Law Revivor
Digital Asset Identification Relief
Interest and Bonus Depreciation Relief
ERC Disallowances and Legal Standing
Substantiation Rules for Emergency Vehicles
Partnership Audits and Due Process
Social Security Repayments
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This week we look at:
Proposed Regulations for IRC Section 530A "Trump Accounts"
IRC Section 6434 Trump Account Pilot Program
Micro-Captive Scrutiny Formalized
BBA Audits: Notice Defects and the Statute of Limitations
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Articles for this week’s update and a copy of the slides for this week can be downloaded below as PDFs:
This week we look at:
Fiduciary and Beneficiary Liability for Unpaid Estate Taxes
Retroactive Entity Classification and Partnership Basis
2026 Passenger Auto Depreciation Limits
Passport Certification & Victimization Defenses
Passport Revocation in Collection Suits
Waiver of Foreign Earned Income Exclusion Time Rules
New Digital Asset Reporting Landscape (Form 1099-DA)
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This week we look at:
Required Minimum Distribution Regulations Delay
CDP Proceedings and Underlying Liabilities
Section 743(b) Adjustments and Economic Substance
Assessability of Section 6038(b) Penalties
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This week we look at:
Supreme Court Invalidates Executive Tariffs Under IEEPA
Special Depreciation Allowance Under the OBBBA
CAMT Adjustments and Relief
Circuit Split on Third-Party Fraud
Valuation and Penalties in Syndicated Conservation Easements
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This week we look at:
TEFRA Jurisdiction and the "Limited Partner" Exception
Artificial Intelligence and Substantiation
Section 183 Profit Motive
Rebate vs. Nonrebate Refunds
Substantiation and Civil Fraud
Consolidated Return Jurisdiction
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This week we look at:
An audio only version of this week's broadcast can be streamed or downloaded below:
PDFs with the articles for this week’s update and this week’s slides can be downloaded below.
This week we look at:
Challenging the Presumption of Delivery (CDP Cases)
Bank Deposits & Conduit Theory
Mandates Under Executive Order 14247 (Notice CP53E)
IRS Implementation of Executive Order 14247 - (FS 2026-02)
Federal Priority Statute Liability
FASIT Structure & Substantial Compliance
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This week we look at:
ERC Refund Suits and Challenges to IRS Notice 2021-20
Section 6015(f) Equitable Relief and Attribution of Income
Financial Disability Tolling under § 6511(h)
Distinguishing "Tax Loss" for Sentencing vs. Restitution
Implementation of Qualified Overtime Deductions (OBBBA)
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This week we look at:
SE Tax Liability for Limited Partners (Sirius Solutions)
Whistleblower Awards and "Collected Proceeds"
Statutory Construction of Section 168(k) Amendments
Updated Safe Harbor Explanations for Section 402(f)
Modernized Group Tax Exemption Framework
Tax-Exempt Status of Supplemental Military Housing Allowances
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This week we look at:
IRS Announces Filing Season Overview & Timeline
A Charity Loses Its §501(c)(3) Status After Forgetting to Perform Virtually Any Exempt Activities
Taxpayer Loses a Large Charitable Contribution Deduction Based on Lack of Substantiation
Second Circuit Concurs With Other Circuits on Willfulness for FBAR Penalties
Tax Court Found Summary Assessment Invalid in Premium Tax Credit Case
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This week we look at:
Standard Mileage Rates & Notice 2026-10
2026 Procedural Updates - Annual Revenue Procedures
Qualified Passenger Vehicle Loan Interest (QPVLI) Proposed Regulations
Estate of Spenlinhauer v. Commissioner Late Filing and More
Bargain Sale of For-Profit colleges to a Non-Profit (501(c)(3))
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This week we look at:
Executive Action on Marijuana Scheduling and IRC § 280E
State Paid Family and Medical Leave (PFML) Programs
Estimated Tax Relief for Qualified Farmland Sales
IRC § 163(j) Interest Limitation Updates
Premium Tax Credit (PTC) Revisions
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This week we look at:
Section 25F Advance Elections
Unreported Income & The "Missing Witness"
Constitutionality of Penalties Post-Jarkesy
Section 280E & Offers-in-Compromise
Substantiating Bad Debt & NOLs
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This week we look at
USPS Changes to Postmark Date System
H.R. 1491: Disaster Related Extension of Deadlines Act
Capitalization Priorities: Temnorod v. Commissioner
Notice 2026-5: HSA Expansion Under OBBBA
Fulfillment by Amazon (FBA) and "Doing Business"
Substantiation Failures: Mirch v. Commissioner
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Articles on this week’s updates can be downloaded as a PDF below.
This week we look at:
Notice 2025-68 – Implementation of Trump Accounts
Draft Form 4547 – Elections and Filing Mechanics
Notice 2025-70 – The OBBBA Scholarship Tax Credit
Alioto v. Commissioner – Corporate Distinctness
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Articles for this week’s broadcast can be downloaded as a PDF below.
This week we look at:
Whistleblower Awards and Substantial Contribution
Corporate Stock Repurchase Excise Tax
Judicial Review of Willful FBAR Penalties
Revisiting the Profit Motive Standard
Judicial Precedent on Erroneous Refund Recovery
OBBBA Guidance on SFCs and Section 987 Elections
The OBBBA Scholarship Tax Credit
Conservation Easements and Gross Valuation Misstatements
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This week we look at:
Innocent Spouse Relief Determination Standards
Adjustments to Medicare Parts A, B, and D
Equitable Distribution vs. Alimony (Pre-TCJA)
Implementation of the Section 139L Interest Exclusion
OBBBA Deductions for Tips and Overtime Compensation for 2025 returns
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Articles for this week’s update can be downloaded as a PDF from the link below:
2025-11-24 Current Federal Tax Developments
This week we look at:
Annual Adjustments to Retirement Plan Limitations
Ensuring Investment Trust Status for Digital Asset Staking Entities
Examining Penalties in Microcaptive Transactions
Ownership Requirements for Non-Business Theft Losses
Defining the Scope of I.R.C. § 172(b)(3) Carryback Waivers
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A PDF with this week’s updates can be downloaded via the link below.
This week we look at:
Conservation Easement Valuation and Highest and Best Use
Trust Fund Recovery Penalty (TFRP) Application
California Residency and Taxpayer Burden of Proof
OBBBA Information Reporting Transition Relief
SCOTUS Oral Argument on IEEPA Tariffs
Conservation Easement Timing and Penalties
Digital Asset Broker Reporting FAQ Guidance
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