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.

2026-07-13 A Week of Final Regulations
Edward K. Zollars, CPA (Arizona)

PDFs of the articles for this week’s update and the slides can be downloaded below: