2024-11-18 End of Partnership Suspense Account at the IRS

This week we look at:

• IRS may stop putting “taxpayer may rely” statements on proposed regulations

• Tax Court rules partnership basis calculations are cumulative in nature and not stand-alone annual calculations under IRC §705

• Latest speculations on what will get through Congress in 2025 - if anything

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

A PDF of this week’s slides and links to supporting documents can be downloaded below:

2024-11-18 Current Federal Tax Developments

2024-11-11 Post Election Issue on Tax Bills and the Reconciliation Process

This week we look at the rules involving the reconciliation process in Congress, the path that it appears most likely any tax bill enacted to deal with the expiration of many TCJA provisions at the end of 2025.

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

The slides for this week’s broadcast can be downloaded from the week below.

2024-11-11 Current Federal Tax Developments

2024-11-04 Retirement Plan Inflation Numbers

This week we look at:

• Retirement plan limits announced by the IRS, basically completing the tax inflation adjustments for 2025

• IRS emailed Chief Counsel Advice outlines dealing with SECA and the net investment income tax issues arising from a BBA partnership exam

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

A PDF with copies of the slides and links to the authorities cited can be downloaded below:

2024-11-04 Current Federal Tax Developments

2024-10-28 IRS Releases Most 2025 Inflation Adjusted Numbers

This week we look at:

• IRS releases inflation adjusted numbers for most items aside from retirement plans for 2023

• IRS has more bad news for those who fail to pay over trust fund taxes to pay other expenses

• Another US District Court denies a preliminary injunction to bar enforcement of the BOI reporting rules

You can stream or download an audio version of the broadcast below.

A PDF of the slides and documents can be downloaded as a PDF via the link below:

2024-10-28 Current Federal Tax Developments

2024-10-21 Staking Returns for One More Try at Court

This week we look at

S corporation finds multiple ways to terminate its S status, asks IRS forgiveness which is granted

• IRS rules condoms are medical expenses for tax purposes

• IRS adds items to list of preventive care an HDHP can pay without the insured having met the annual deductible

• PTIN registration opens for 2025

• Staking income challenge returns to court

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

A copy of the slides and citations can be downloaded via the link below:

2024-10-21 Current Federal Tax Developments

2024-09-09 More BOI Report Issues

This week we look at:

• Additional BOI clarifications from online discussions regarding a CPA firm’s reporting obligations and confusions about reporting by entities that don’t register with a state for formation but which do file tax returns

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

The slides and citations for this week’s broadcast can be downloaded as a PDF below.

2024-09-09 Current Federal Tax Developments

2024-09-03 BOI Review Time

This week we look at:

• DOJ has scheduled a December 2 hearing on the proposed rule to reschedule marijuana

• BOI reporting confusions that keep coming up as questions in online discussions - time to review

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

A PDF with this week’s slides and citations can be downloaded below.

2024-09-03 Current Federal Tax Developments

2024-08-26 IRS ERC Notices of Denial-Comments of the Taxpayer Advocate

This week we look at:

• IRS announces the reopening of the ERC Voluntary Disclosure Program on somewhat less generous terms then the first program provided

• National Taxpayer Adviser discusses issues related to ERC Notices of Disallowance issued by the IRS

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

A PDF with slides and this week’s links to cited documents can be downloaded below.

2024-08-26 Current Federal Tax Developments

2024-08-12 Internet Frauds and Section 165

This week we look at

• Online scams and tax deductions - why how that online scammer you found on a dating site manages to take your money can make a big tax difference

• IRS announces next steps in ERC program, will begin sending some checks in September

An audio only version of this week’s session can be downloaded and streamed below:

A PDF with copies of the slides and citations can be downloaded below:

2024-08-12 Current Federal Tax Developments

2024-08-05 House Passed Tax Bill Fails to Clear Cloture Vote in the Senate

This week we look at: 

• Tax bill fails to clear a procedural vote in the Senate, reducing the likelihood we’ll see the bill enacted before this Congress leaves office

• US District Court declines to issue preliminary injunction requiring the IRS to terminate the ERC claim moratorium, but finds much the court liked in the plaintiff’s arguments.

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

A PDF with this week’s slides and citations can be downloaded from the link below.

2024-08-05 Current Federal Tax Developments

2024-07-29 More IRS ERC Guidance

This week we look at:

• FinCEN adds two more questions to BOI FAQ page

• IRS adds five new warning signs for problematic ERC claims and announces new developments coming in ERC enforcement

• Chief Counsel Memorandum outlines position on tax exempt organizations dealing with §52 provisions for ERC

An audio only broadcast can be streamed or downloaded below:

A copy of the sides and links to the cited documents can be downloaded as a PDF below:

2024-07-29 Current Federal Tax Developments

2024-07-22 IRA Finalizes RMD Regulations

This week we look at:

• Taxpayer can’t simply rely on tax software when preparing their return, even if they aren’t being nominated for Secretary of Treasury

• IRS finalizes SECURE Act/SECURE 2.0 Act required minimum distributions regulations

• IRS proposed regulations address the problem of determining the applicable age for those born in 1959

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

A PDF with the citations for this week’s podcast can be downloaded below:

2024-07-22 Current Federal Tax Developments

2024-07-15 BOI Updates

This week we look at:

• FinCEN updates the FAQs for BOI reporting, adding information about entities that cease to exist

• New Jersey Committee on Unauthorized Practice of Law releases letter outlining when CPAs and EAs may prepare and/or file BOI reports for clients without the assistance of an attorney

• Another PLR issued for missed ESBT elections for trusts that qualified to make such elections

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

A PDF with the slides and citations for this week’s broadcast can be downloaded below:

2024-07-15 Current Federal Tax Developments

2024-07-08 Supreme Court Makes It Easier to Challenge Regulations

This week we look at

• End of term US Supreme Court cases that will likely impact challenges to Treasury regulations, overturning the concept of Chevron deference and extending the statute to challenge regulations under the Administrative Procedures Act

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

A PDF with a copy of this week’s slides and citations can be downloaded below:

2024-07-08 Current Federal Tax Developments

2024-07-01 IRS to Eventually Automate FTA Relief

This week we look at:

• Ninth Circuit rules that statute of limitations for the IRS to sue for recovery of erroneous refund begins when the check clears the Federal Reserve and is approved for payment by the US Treasury

• IRS National Taxpayer Advocate announces the IRS will automate FTA abatement of penalties beginning in 2026

• Attorneys report some ERC claimants now interesting in filing suit to accelerate their claim processing

An audio version of this week’s braodcast can be streamed or downloaded below.

A PDF with the slides and citations can be downloaded below.

2024-07-01 Current Federal Tax Developments

2024-06-24 Supreme Court Upholds the 965 Transition Tax

This week we look at:

• Supreme Court rules, in a more divided than it may appear opinion, that the §965 transition tax is Constitutional, sustaining the result from the Ninth Circuit in the Moore case.

• IRS gives interim guidance for special distribution relief in the SECURE Act 2.0 for certain distributions.

• IRS indicates it will now be (slowly) processing ERC claims, vast majority show issues

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

A PDF with the citations and copy of the slides for this week can be downloaded below:

2024-06-24 Current Federal Tax Developments

2024-06-17 Do Not Believe Your Chatbot on Tax Matters

This week we look at:

• IRS provides last minute relief for payment of second quarter corporate estimated tax payments related to corporate alternative minimum tax

• En-banc rehearing request denied in case of Farhy v. Commissioner by DC Circuit

• CPA pleads guilty to tax charges related to syndicated conservation easement program

• Taxpayer Advocate warns of relying on generative AI for answering tax questions for consumer tax software - and there are just as big of issues for tax professionals

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

The citations and slides for this week’s broadcast can be downloaded as a PDF form the link below:

2024-06-17 Current Federal Tax Developments

2024-06-10 Estate Tax Problems for Buy Sells Funded by Life Insurance

This week we look at:

• US Supreme Court rules that a requirement to redeem the decedent’s shares cannot be considered to reduce the value of the entity, but life insurance proceeds received by the entity to fund the buyout will increase the value

• Taxpayer denied relief for late rollover when funds were accidentally transferred from employer plan to Roth IRA

• IRS rules certain payments related to East Palestine, Ohio derailment are §139 disaster payments

• What options exist for an employer with a pending ERC claim?

An audio only broadcast for this week’s update can be streamed or downloaded below:

A PDF with the slides and links to the documents cited can be downloaded below.

2024-06-09 Current Federal Tax Developments

2024-06-03 LLC as an S Corporation Issue

This week we look at:

• IRS announces that Direct File will continue into 2025 and be expanded while maintaining other programs

• A taxpayer finds its not so simple as just file a Form 2553 if you want to have an LLC taxed as an S corporation, but did realize the error fast enough to get a PLR to restore S status

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

A copy of the slides and this week’s link to items mentioned can be downloaded below:

2024-06-03 Current Federal Tax Developments

2024-05-27 Misleading Silences Are Sometimes Fine in Tax

This week we look at:

• Yet another PLR requested for missed QSST election after S shares moved to trust following death of a shareholder

• Tax preparer’s conviction for willfully filing false returns upheld on appeal despite his argument he had doing what he did for years

• Letters to taxpayer from IRS Appeals did not extend the time to file suit for a claim for refund

• A partnership had properly elected to use BBA audit provisions early, rendering IRS FPAA invalid

An audio only update for htis week’s session can be streamed or downloaded below:

A PDF with the slides and this week’s links can be downloaded below:

2024-05-27 Current Federal Tax Developments