2026-07-13 A Week of Final Regulations
This week we look at:
Transitioning from First Time Abate (FTA) to Automatic Exemption from Penalty (AEP)
Strict Enforcement of Tax Refund Statutes of Limitations
Employee Retention Credit (ERC) Refund Claims & Pleading Standards
Pandemic-Era Persistence of New York's Convenience of the Employer Rule
Invalidity of Treasury Regulation Section 1.951A-2(c)(5)
Non-Shareholder Capital Contributions vs. Compensation
Final Section 1035 Exchange & Corporate Reorganization Regulations
Reclassification of Abusive CRAT Structures as Listed Transactions
The National Taxpayer Advocate’s Perspective on AEP
An audio only version of this week’s broadcast can be downloaded or streamed below.
PDFs of the articles for this week’s update and the slides can be downloaded below:
