This week we look at:

Transitioning Foreign Tax Allocations and Implementing the Ten Percent Credit Disallowance Under Section 960(d)(4)
Trustee-to-Trustee Transfers of Inherited IRAs Through an Estate: Technical Analysis of PLR 202631001
Federal Courts Lack APA Jurisdiction Over Foreign Gift Penalty Disputes: The Adequate Alternative Remedy Barrier
Sourcing Executive Termination Payments: Analyzing the Bifurcated Sourcing of Severance and RSUs in the Appeal of Otting
The Permanent Section 45S Paid Family and Medical Leave Credit: Analyzing the Statutory Wage Method Mechanics and the New Premium Method Under Notice 2026-28
The Tax Court Open Door: Why the BBA Partnership Petition Deadline Is Not Jurisdictional
Commingled Funds, Unsubstantiated Deductions, and the Binding Form of Transactions: A Technical Tax Analysis of Reed v. Commissioner
The Safe Harbor That Wasn’t: Deconstructing the Anti-Abuse Rule in SIH Partners LLLP v. Commissioner
The Evolution of Qualified Overtime Compensation Deductions: Analyzing IRS Fact Sheet FS-2026-13 and Its Practical Implications

An audio only version of this week’s broadcast can be streamed or downloaded below:

This week’s articles can be downloaded below: