https://vimeo.com/1215009645?share=copy&fl=sv&fe=ci

https://www.currentfederaltaxdevelopments.com/podcasts/2026/8/2/2026-08-03-on-again-off-again-on-again-plr

This week we look at:

  • IRS Reinstates Tax Deferral on Variable Annuity Term Certain Options: Reconsideration and Reversal in PLR 202630002
  • Understanding the ERC Pleading Standard: Federal Claims Court Deferral in I Health and Life Insurance Services
  • Predecessor Losses, the Lonely Parent Rule, and the Limits of Economic Reality: Analysis of HBM Holdings Co. v. Commissioner
  • Double Books and Disguised Payees: Corporate Personal Expenses and the Civil Fraud Penalty in Prezioso v. Commissioner