Current Federal Tax Developments: Recent Episodes

Edward Zollars, CPA

Weekly update on federal income tax developments

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This week we look at:

  • Understanding Automatic Accounting Method Changes-Revenue Procedure 2025-23
  • Accounting Method Changes in Conmac Investments, Inc.
  • Conservation Easements in Glade Creek Partners, LLC
  • Tax Treaty Exemptions in Kramarenko v. Commissioner
  • Tax Refund Litigation & Variance Doctrine in Shleifer v. U.S.
  • Tax Court Jurisdiction in Commissioner v. Zuch
  • Digital Asset Reporting & Withholding in Notice 2025-33

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

A PDF with articles on this week’s developments can be downloaded below:

2025-06-16 Current Federal Tax Developments

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This week we look at:

  • Navigating Corporate Alternative Minimum Tax (CAMT)
  • Conservation Easement Valuation & Penalties: A Warning from Tax Court
  • Collection Due Process (CDP) & Offers in Compromise (OICs): Lessons from Tax Court
  • Accuracy-Related Penalties: Navigating Negligence and Insufficient Professional Reliance
  • Understanding Treasury’s Request for Information on Modernizing Federal Payments
  • Worthlessness vs. Discharge: A Ninth Circuit Examination of Bad Debt Deductions Concurrent with COD Income
  • Navigating the Religious Exemption Landscape: A Deep Dive into Unemployment Compensation Tax

An audio-only version of this week broadcast can be streamed or downloaded via the link below:

This week’s articles on the updates are available in the PDF that can be downloaded below:

2025-06-09 Current Federal Tax Developments

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This week we look at:

  • Self-Employment Tax for Limited Partners (Soroban II)
  • Presidential Tariffs Under IEEPA (USCIT Decision & Federal Circuit Stay)
  • Massachusetts Source Income (Welch Case Petition)
  • Foreign Gift Penalties (Huang Case)

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

Audio Block Double-click here to upload or link to a .mp3. Learn more A PDF with the articles for this week’s updates can be downloaded below:

2025-06-02 Current Federal Tax Developments

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This week we look at:

  • IRS Reduces Estate Tax Closing Letter Fee
  • Tax Court Scope of Review in Passport Cases
  • Marital Deduction for Bequests to Trust
  • “Reasonable Cause” in Late-Filing Penalty Cases
  • “No Tax on Tips Act” (S.129) Passes Senate
  • Transfer Pricing in Facebook, Inc. & Subsidiaries v. Commissioner
  • Navigating New York’s Convenience Rule: Insights from Matter of Zelinsky

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

A PDF with the text of articles on this week’s update can be downloaded below.

2025-05-26 Current Federal Tax Developments

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This week we look at:

  • IRC Section 7433 and the Scope of the Collection Waiver of Sovereign Immunity
  • The Claim of Right Doctrine Applied to Business Errors
  • IRC Section 7433: Reinforcing Collection vs. Assessment Distinction
  • Selected issues from The One, Big, Beautiful Bill’s tax provisions
  • Proposed Changes to the Section 199A Qualified Business Income Deduction
  • Proposed Changes Affecting Passthrough Entities and State PTE Taxes

  • Interest Deductions and Penalties in Complex Financial Transactions

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

A PDF with articles on this week’s developments can be downloaded below.

2025-05-19 Current Federal Tax Developments

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This week we look at:

  • Deductibility of IVF and Gestational Surrogacy Costs
  • Fraudulent Tax Claims & 28 U.S.C. § 2514
  • Tax Collection Suits & Statute of Limitations in United States v. Ragen
  • Moving Expense Deduction - Civilian Department of Defense Contractor Eligibility
  • Tax Court Jurisdiction - The 90-Day Deadline for Deficiency Petitions

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

A PDF with this week’s articles can be downloaded below:

2025-05-12 Current Federal Tax Developments

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This week we look at:

  • ERC Claims Filed Without Schedule R
  • Reasonable Cause for Information Return Penalties: Reliance on Software
  • Proposed Expansion of P.L. 86-272 "Solicitation of Orders" Definition
  • 2026 Inflation Adjustments for HSAs and Excepted Benefit HRAs

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

A PDF with articles on this week’s updates can downloaded as a PDF below:

2025-05-05 Current Federal Tax Developments

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This week we look at:

  • Navigating the Overlap: Civil Tax Assessments and Criminal Restitution Orders
  • Navigating Innocent Spouse Relief: A Look at Salvi v. Commissioner
  • Supreme Court Weighs Tax Court Jurisdiction in Levy Disputes After Tax Payment: A Deep Dive into Commissioner v. Zuch
  • Navigating ERISA Prohibited Transaction Claims: Insights from Cunningham v. Cornell University

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

Articles on this week’s updates can be downloaded as a PDF below:

2025-04-28 Current Federal Tax Developments

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This week we look at:

  • Navigating the 90-Day Deadline for Employment Tax Redeterminations: The Belagio Fine Jewelry, Inc. Case and Equitable Tolling
  • GWA, LLC v. Commissioner: Substance Over Form and the Nuances of Tax Elections for Disregarded Entities
  • Notice 2025-23: Treasury and IRS Signal Withdrawal of Basis Shifting TOI Regulations and Related Penalties
  • Hobby Loss and Failure to File: A Deep Dive into Himmel v. Commissioner

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

Articles on this week’s developments can be downloaded as a PDF below:

2025-04-21 Current Federal Tax Developments

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This week we look at:

  • Massachusetts Source Income and the Sale of Stock by a Nonresident
  • Navigating the Valuation Landscape: Insights from Pierce v. Commissioner
  • Personal Liability for Corporate Sales and Use Tax: An Analysis of Matter of the Appeal of B. Wageman
  • Navigating the IRS’s ERC Claim Processing Moratorium and "Risking" Procedures
  • Jurisdictional Prerequisites in Tax Refund Suits: A Case Study of Estate of Robert F. Armitage, Deceased v. The United States
  • Dependency Claims and Child Tax Credits: A Look at Correll v. Commissioner
  • WT Art Partnership LP v. Commissioner: Charitable Contribution Deductions and Valuation Pitfalls
  • Zajac v. Commissioner: Disallowance of Numerous Deductions and Upholding Penalties
  • Hampton v. Commissioner: Public Policy and Disallowance of Shareholder Loss Deduction
  • Revised SIFL Rates for Valuation of Noncommercial Flights: Revenue Ruling 2025-9
  • IRS Provides Limited Penalty Relief for Certain Micro-Captive Disclosure Statements
  • The Demise of DeFi Broker Reporting: An Analysis of H.J. Res. 25

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

A PDF with articles on this week’s update can be downloaded below:

2025-04-16 Current Federal Tax Developments

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This week we look at:

  • Ranch Springs, LLC v. Commissioner: A Case Study in the Valuation of Conservation Easements and the Pitfalls of Aggressive Tax Planning
  • The Duty of Consistency Prevails: A Case Study in Innocent Spouse Relief and Subsequent Asset Claims
  • Navigating the Murky Waters of Investment Tax Credits and Passive Activity Rules: A Deep Dive into Strieby v. Commissioner

An audio only broadcast can be downloaded or streamed below:

Articles on this week’s developments and citations can be downloaded below:

2025-04-07 Current Federal Tax Developments

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This week we look at:

  • Congress Passes Resolution to Nullify Final Regulations on DeFi Information Reporting in TD 10021
  • Interim Final Rule Limiting BOI Filing Requirements Released by Treasury Department
  • Substantiating Depreciation for Converted Property: A Look at Smith v. Commissioner
  • Executive Order Will Generally Bar the Use of Paper Checks to Make Payments to or Receive Refunds from Treasury, Including Tax Related Ones
  • Jones et al. v. Commissioner: A Deep Dive into the Tax Court’s Scrutiny of a Microcaptive Insurance Arrangement
  • Navigating Jurisdictional Hurdles in Tax Refund Claims: A Look at Hamilton v. United States
  • Ninth Circuit Affirms Willful Failure to Pay Trust Fund Taxes: A Case Study for CPAs

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

Articles on this week’s update can be downloaded below:

2025-03-31 Current Federal Tax Developments

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This week we look at:

  • TIGTA Report: IRS Refund Claim Processing for Deceased Taxpayers
  • IRS Certification of Seriously Delinquent Tax Debt to the State Department
  • Refund Claim Challenges: When IRS Guidance Fails
  • Sixth Circuit: IRA Forfeiture to Government Not Taxable
  • Loper Bright: Pharmacy Benefit Managers Denied DPAD Deduction
  • IRS ERC Update: Simplified Income Tax Reporting for Wage Reduction

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

The articles for this week’s developments can be downloaded below:

2025-03-24 Current Federal Tax Developments

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This week we look at:

  • Tax Court Finds Taxpayer Failed to Provide a Qualified Appraisal, No Charitable Deduction Allowed
  • Estate Found Liable for $2 Million FBAR Penalty That Applied to the Decedent
  • Taxpayers Filing Court Challenges to Attempt to Obtain Employee Retention Tax Credits
  • Fourth Circuit Overturns Trial Court’s Grant of Summary Judgment to the Government, Finding True Issue of Fact Exists Regarding Whether Statute Remained Open
  • IRS Memorandum Discusses When a Taxpayer Can Claim a Deduction as Victims of Various Scams Under Current Law

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

Articles on this week’s developments can be downloaded from the link below:

2025-03-17 Current Federal Tax Developments

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This week we look at:

  • Treasury and the Corporate Transparency Act (BOI Reporting)
  • Martino v. Commissioner: Alimony Deduction Case
  • Estate of Kalikow v. Commissioner: Estate Tax & Settlement Payments
  • Appeal of A. Markowski: California Source Income for Nonresidents
  • CF Headquarters Corporation v. Commissioner: Taxability of Grants
  • United States v. Gora: IRS Levy Enforcement

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

Articles for this week’s developments can be downloaded from the link below:

2025-03-10 Current Federal Tax Developments

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This week we look at:

  • FinCEN Announcement on BOI Reporting Penalties
  • Tax Court Case: Alan Hamel and Estate of Suzanne Hamel v. Commissioner
  • IRS “Dirty Dozen” Tax Scams for 2025
  • IRS Adds Tax Documents to Online Accounts
  • Ways and Means Committee Passes Disaster Relief Bills
  • House and Senate Budget Resolutions

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

A copy of the articles for this week’s broadcast can be downloaded below:

2025-03-03 Current Federal Tax Developments

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This week we look at:

  • Second Circuit Rules on Section 179D Deductions and Accounting Method Change
  • IRS Guidance on ACA Notice Posting
  • Court Case on CPA Negligence and Trust Return Penalties
  • BOI Reporting Requirement Updates

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

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

2025-02-25 Current Federal Tax Developments

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This week we look at:

  • Deductibility of Losses: Weston v. Commissioner
  • Conservation Easements: Green Valley Investors LLC
  • Automobile Depreciation and Lease Inclusion
  • S Corporation Inadvertent Termination Relief
  • Corporate Transparency Act (CTA) - Government Briefs
  • House Ways & Means Committee Tax Bills

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

The articles for this week’s update can be downloaded below:

2025-02-16 Current Federal Tax Developments

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This week we look at:

  • IRS issues letter ruling on IRA left to trust
  • A taxpayer mistakenly believes the IRS had conceded that his income was not subject to self-employment tax, but it hadn’t
  • The Tax Court denies a taxpayer’s deductions and claimed partnership losses due to incredibly disorganized and inadequate records
  • Taxpayer runs afoul of the “pay first, litigate later” rule when attempting to sue the IRS for a refund in US District Court in response to an assessment
  • A taxpayer’s unprocessed claim for an ERTC refund doesn’t justify CDP relief
  • The BOI - new Administration continues litigation and proposes a new due date, potential filing relief

An audio only version of this week's broadcast can be downloaded or streamed from the link below.

Article for this week’s developments are available as a PDF from the link below.

2025-02-10 Currrent Federal Tax Developments

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This week we look at:

  • Tax Court Finds Property Donated to Charity Had a Value Less than One-Third of What Taxpayers Claimed on Return
  • IRS Finds Most Expenses Related to Taxpayers’ In Vitro Fertilization and Surrogacy Will Not Be Deductible Medical Expenses Under IRC §213
  • Taxpayer Denied Innocent Spouse Relief in Tax Court Bench Opinion
  • Tax Court Finds No Issue With the Appeals Office Structure and Staffing
  • Failure to Provide Proof of Filing of Returns Fatal to Taxpayer’s Attempt at Obtaining Relief in CDP Hearing Despite IRS Procedural Errors

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

Articles for this week’s update can be downloaded as a PDF below:

2025-02-03 Current Federal Tax Developments

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This week we look at:

  • Funds Taken By Sheriff Were a Valid Loan and Not Income from Embezzlement
  • Tax Court Allows a Reduced Deduction for a Conservation Easement
  • CCA Discusses Issues with Activities of a Private Foundation with Regard to Self-Dealing, Attempted Correction and Jeopardizing Investments
  • IRS Email Discusses Agency’s (Lack of) Obligation to Process Amended Tax Returns
  • Supreme Court Reverses Fifth Circuit Merits Panel, Again Removes Emergency Injunction Against Enforcement of the CTA BOI Reports
  • Despite Supreme Court’s Action on Texas Top Cop Shop, Inc. Ban on Enforcement of BOI Reporting, FinCEN Notes Ban on Enforcement Under the Smith Case is Still in Effect

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

A PDF with stories on this week’s developments can be downloaded below:

2025-01-27 Current Federal Tax Developments

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This week we look at:

  • IRS updates residential energy credit Fact Sheet, adds details about the PIN requirements that take effect for 2025 property
  • Proposed regulations on catch-up contributions added by the SECURE 2.0 Act
  • Proposed regulations on the automatic enrollment provisions of IRC §414A
  • US Supreme Court agrees to review a Third Circuit ruling on Tax Court jurisdiction in a Collection Due Process case
  • IRS issues final regulations on resolution of tax controversies by the IRS Independent Office of Appeals Under TFA of 2019

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

Articles on this week’s developments are contained in the PDF that can be downloaded below.

2025-01-20 Current Federal Tax Developments

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This week we look at:

  • IRS Grants Tax Relief to California Wildfire Victims
  • National Taxpayer Advocate’s Report to Congress and Legislative Recommendations Released
  • Third US District Court Issues BOI Reporting Injunction
  • Tax Court Finds a Building Was Not a Certified Historic Structure as Defined by §170(h)
  • Taxpayer Denied Refund as Court Found the Taxpayer Had Taken the Position That Its Reporting Was an Error Rather Than a Method of Accounting
  • Seventh Circuit Upholds Imposition of Fraud Penalty for an Overstatement of Withholdings
  • Court Finds Taxpayer Submitted Digitally Altered False Documents, Sustained the Fraud Penalty the IRS Proposed
  • IRS Updates Guidance on Section 530 Employment Tax Liability Relief

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

Articles on the developments for this week’s broadcast can be downloaeded below:

2025-01-13 Current Federal Tax Developments

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This week we look at:

  • IRS gives relief for specific identification of digital asset basis for certain taxpayers for 2025 only
  • Department of Justice asks the U.S. Supreme Court to Stay the Latest Corporate Transparency Act Injunction
  • IRS no longer to dispute requirement to comply with APA to add listed transactions after the enactment AJCA in 2024
  • Tax Court rules that merely being in a registered historic area does not make a building a certified historic structure
  • Tax Court finds taxpayer owes tax on over $5.3 million diverted from two retirement plans

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

A PDF of the slides and links to articles regarding the developments can be downloaded below.

2025-01-05 Current Federal Tax Developments

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This week we look at:

  • Tomato processing plant reconditioning to put plant back into shape before beginning next harvest-season production failed all events test at end of the prior season
  • Tax Court again imposes functional test in case with state law limited partners
  • The BOI reports have a week of dueling court rulings - from the same court

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 can be downloaded below:

2024-12-30 Current Federal Tax Developments

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This week we look at:

  • Automatic accounting method changes related to §174 extended to years beginning in 2024
  • BOI report - hectic week, but ultimately no resolution yet for initial report due date
  • 2025 mileage rates published by the IRS
  • IRS finalizes regulations on supervisory approval of penalties
  • IRS proposes revisions to Circular 230

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

A PDF with the slides and citations can be downloaded viaa the link below:

2024-12-23 Current Federal Tax Developments

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This week we look at:

  • President signs the two tax bills Congress recently passed
  • DOJ asks for stay of injunction issued by US District Court in Texas on enforcement of the CTA
  • IRS expands Business Tax Account access and services that can be accessed via that account

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

2024-12-16 Current Federal Tax Developments

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This week we look at:

  • Congress enacts two tax laws: but neither is the big one that passed the House in January but stalled in the US Senate
  • A Texas US District Court has issued a nationwide temporary injunction barring FinCEN from enforcing the BOI reporting regime
  • DOJ files a notice of Appeal of the Texas Top Cop Shop Inc decision and FinCEN posts information regarding the impact of the case on BOI reports

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

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

2024-12-09 Current Federal Tax Developments

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This week we look at:

  • IRS releases optional form taxpayer can use to make an IRC §83(b) election
  • IRS extends for one year more a transitional 45-day period to perfect research credit claims found to be invalid claims
  • IRS provides additional relief on the issuance of Forms 1099-K

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

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

2024-12-02 Current Federal Tax Developments

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This week we look at:

  • IRS announces program using IP-PIN to allow taxpayers who find a dependent on their return has already been listed on another to get their return processed immediately
  • The ERC Second Voluntary Disclosure Program ends but the IRS gives some additional relief for withdrawing a claim filed via third-party payer such as a payroll service

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.

2024-11-25 Current Federal Tax Developments

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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This week we look at:

  • DOJ issues proposed rule that would remove cannabis businesses from loss of most business deductions under IRC §280E
  • Filing date relief issued for those impacted by Ohio tornadoes from March
  • IRS National Fraud Counsel speaks on ERC exams in ABA Tax Section webinar
  • Tax adviser files suit to attempt to force the IRS to start processing ERC claims
  • Tax Court imposes penalty for raising frivolous claims against taxpayer who argued wages are not income (among other things)

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

A PDF with a copy of the slides and links to the supporting documents can be downloaded below:

2024-05-20 Current Federal Tax Developments

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This week we look at:

  • IRS gives update on final results for ERC voluntary compliance program and discusses the future
  • The taxpayer’s contract did not make payment contingent on the success of research
  • DOJ announces CPA firm barred from promoting CRAT/single premium annuity shelter
  • IRS provides information on CAF “under review status” and changes to requesting transcripts

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

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

2024-04-13 Current Federal Tax Developments

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This week we look at:

  • IRS releases Fact Sheet on disaster provisions for retirement accounts added by SECURE 2.0 Act
  • DC Circuit reverses Tax Court ruling that IRS does not have assessment authority for failure to file a report under IRC §6038(b) (Form 5471)
  • Electric vehicle final regulations issued
  • Department of Justice begins process to move marijuana from Schedule I to Schedule III which would cause §280E to no longer limit deductions for cannabis businesses
  • Lack of any written records on time President/COO spent on activities or even estimate time spent on qualified research activities doomed attempt to claim a credit under IRC §41(a)

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

A PDF of this week’s slide and citation links can be downloaded below:

2024-05-06 Current Federal Tax Developments

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This week we look at:

  • Final regulations issued on credit transfer provisions of the Inflation Reduction Act
  • Tax Court rules the law does mandate a minimum level of attention by a supervisor when approving a proposed penalty
  • IRS announces the end of the Direct File pilot and will announce the next steps shortly

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

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

2024-04-29 Current Federal Tax Developments

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This week we look at:

  • IRS again waives penalties for certain RMD distributions for inherited IRAs and retirement plans, but indicates this should be the last time
  • FinCEN adds more Q&As to BOI FAQ for the first time since January

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

Slides and links to the source documents can be downloaded as a PDF via the link below.

2023-04-22 Current Federal Tax Developments

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This week we look at

  • Tax Court reverses position on validity of a regulation it had upheld four years ago
  • US Supreme Court hears oral arguments in case involving estate tax value of a corporation that received life insurance to redeem the majority shareholder’s estate
  • IRS Criminal Investigation Divisions announces update on COVID relief related investigations and convictions

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

A PDF with the links and slides can be downloaded below:

2024-04-01 Current Federal Tax Developments

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This week we look at:

  • As ERC voluntary compliance program ended, IRS release discusses agency’s plans going forward
  • Senate Finance Chair Wyden indicates there be a cloture vote in the Senate on House passed tax bill
  • IRS issues proposed regulations to make SPA CRAT arrangements listed transactions
  • IRS asks Supreme Court to overturn Culp decision

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

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

2024-03-25 Current Federal Tax Developments

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This week we look at:

  1. FinCEN gives formal notice of appeal of CTA BOI case
  2. Deadline rapidly approaching for entering first ERC voluntary disclosure program
  3. Arizona lawmakers write the IRS about tax status of 2023 state rebates
  4. Court of Appeals finds it is barred from hearing appeal of Tax Court dismissal of small case/

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

2024-03-18 Current Federal Tax Developments

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This week we look at:

  • FinCEN announces position on handling BOI enforcement following National Small Business United v. Yellen
  • IRS issues warning about companies peddling “doctor’s notes”
  • Tax Court warns taxpayer about litigating an issue the taxpayer had previously litigated and lost on for a prior year

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

A copy of the slides and links to citations can be downloaded below:

2024-03-11 Current Federal Tax Developments

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This week we look at:

  • CTA found to violate Constitution by US District Court
  • Tax Court issues ruling on impact of SECURE 2.0 Act statute change on returns filed before December 29, 2022 effective date of the Act
  • IRS warns about need to reconcile premium tax credit on Forms 1040 after seeing an increase in the number of returns being filed without the required reconciliation

Citations and slides for this week’s update can be downloaded below:

2024-03-04 Current Federal Tax Developments

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This week we look at:

  • More BOI resources from CAMICO made available by NJCPA
  • District Court refuses to stay FBAR proceeding to await Tax Court result partially due to the age of the taxpayer
  • IRS announces program to go after corporate jet personal usage
  • The state of Arizona sues the IRS over tax status of state tax rebate.

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

This week’s slides and links to source documents can be downloaded below:

2024-02-26 Current Federal Tax Developments

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This week we look at:

  • Insurers updating their advice on BOI engagements
  • SALT cap 2023 increase bill fails on a procedural vote in the House
  • Jury finds taxpayer did not willfully fail to file FBAR reports
  • IRS takes position third party payors liable for ERC refund repayment in addition to common law employers
  • IRS sending out CP271 “soft letters” to those with open ERC refund claims
  • S corporation has a failure of 9 trusts receiving shares from decedent
  • Taxpayer unsuccessfully argues she only should pay taxes on social security actually received

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

This week’s slides and citations can be downloaded as a PDF below:

2024-02-19 Current Federal Tax Developments

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This week we look at

  • No movement on tax bills this week - nor is final action at all likely to take place before March
  • E-Filing returns - good or bad idea? Two competing articles published this week
  • Taxpayer owes tax on IRA forfeited to government as part of criminal conviction
  • IRS discusses when CID voluntary disclosure program should be used instead of ERC voluntary disclosure program
  • IRS warns about EFIN scam emails
  • Taxpayer found to have submitted a late new refund claim rather than a revision to a timely filed informal claim

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

A PDF copy of the slides and links can be downloaded below:

2024-02-12 Current Federal Tax Developments

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This week we look at:

  • Bipartisan extender bill is passed by the House, but faces uncertain future in the Senate
  • A limited, single-year SALT cap relief bill will be brought to the House floor as part of the compromise to pass the bipartisan bill
  • Tax filing season for 2023 return begins this week
  • A cautionary tale about phishing being used to obtain client tax information

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

The slides and links to information are available to download below:

2024-02-05 Current Federal Tax Developments

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This week we look at a proposed tax bill that has advanced out of the House Ways & Means Committee.

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

A copy of the slides with links to materials can be downloaded below.

2024-01-29 Current Federal Tax Developments

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This week we look at:

  • Talks continue on proposed tax bill
  • IRS provides guidance on Pension-Linked Emergency Savings Account anti-abuse provisions
  • Relief granted for filing information found in Part IV of Form 8308 for 2023 returns
  • IRS updates Notice describing how to obtain certain exemptions from the required electronic filing of certain entity information and tax returns

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

The citations for this week’s program can be downloaded below:

2024-01-16 Current Federal Tax Developments

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This week we look at:

  • New work in progress to try and obtain a bipartisan tax bill
  • IRS gives car dealers a brief extension to file time-of-sale reports
  • IRS reverses direction on treatment of impact of adding a tax reimbursement clause to an IDGT
  • Taxpayer can rely upon date IRS places in Notice of Deficiency as the last day to file a Tax Court petition

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

Articles on this week’s updates can be downloaded below:

2024-01-08 Current Federal Tax Developments

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This week we look at FinCEN's release of the BOI E-Filing site on January 1, 2024.

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

A copy of this week’s slides and the BOI form can be downloaded via the links below:

2024-01-02 Current Federal Tax Developments

FinCEN Beneficial Ownership Information Form

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This week we look at:

  • IRS announces a three month Employee Retention Credit Voluntary Disclosure Program
  • IRS provides relief from failure-to-pay penalties for 2021 and 2020 taxes for certain situations
  • Taxpayer uses the wrong FedEx service, therefore his Tax Court petition was not filed on time

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

Articles related to this week’s updates can be downloaded below:

2023-12-26 Current Federal Tax Developments

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This week we look at:

  • FinCEN adds more information to FAQ page, including information on PDF form
  • Bill passes House that would give a limited extension of time for some initial BOI reports to be filed
  • IRS releases mileage rates for 2024
  • Supreme Court agrees to hear estate tax valuation case to resolve split in the Circuits

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

Slides and links to articles for this week’s update can be downloaded below.

2023-12-18 Current Federal Tax Developments

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This week we look at:

  • IRS sends out a batch of 20,000 ERC rejection letters
  • Employer files suit claiming IRS ERC guidance violated the Administrative Procedures Act
  • SCOTUS hears oral arguments in the Moore case
  • Draft K-2/K-3 instructions are published with no major changes to the domestic filing exception for 2023

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

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

2023-12-11 Current Federal Tax Developments

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This week we look at:

  • FinCEN finalizes extension of due date for initial BOI reports for entities created in 2024
  • Tax Court rules that a state law limited partner is not automatically covered by IRC §1402(a)(13) self-employment tax exemption
  • OPR due diligence alert on FBAR
  • Annual business MeF shutdown date announced IRS denies request for automatic accounting method change late election relief
  • Tax Court finds that if date to file a Tax Court petition falls on a date that the clerk’s office is inaccessible, the taxpayer qualifies for extended filing relief even though electronic option had been available on the due date

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

A copy of the slides and links to the materials can be downloaded below:

2023-12-04 Current Federal Tax Developments

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This week we look at:

  • IRS delays certain parts of expanded Form 1099-K filings added in ARPA to 2024 tax years
  • FinCEN enters the ERC fraud enforcement game, publishing 10 red flags for financial institutions to use to identify suspicious transactions that may need to be reported to FinCEN

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

Slides and links to materials for this week’s update can be downloaded below:

2023-11-27 Current Federal Tax Developments

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This week we look at:

  • IRS clarified FAQ on §139A and backpay for wrongfully incarcerated members of the armed services
  • FinCEN adds to the FAQ on beneficial ownership information reporting

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

This week’s slides and citations can be downloaded below:

2023-11-20 Current Federal Tax Developments

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This week we look at:

  • Inflation adjusted numbers for 2024 issued by the IRS
  • Minor revisions made in final BOI FinCEN Identifier rules
  • The IRS issues its second ERC-related GLAM, this time taking aim at OSHA related partial shutdown theories
  • If a Notice isn’t binding on the courts, does that mean we can just pretend it doesn’t exist when advising our clients?

The slides and links to documents and articles can be downloaded below.

2023-11-13 Current Federal Tax Developments

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This week we look at:

  • 2024 inflation adjusted retirement numbers released by the IRS
  • MeF 1040 shutdown date announced by the IRS
  • Trust found liable for transferee tax in failed Son-of-BOSS shelter to offset stock sale gain
  • IRC §41 refund claim grace period extended for yet another year
  • Tax Court refuses to expand equitable relief for missing 90-day deadline to file petition

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

A copy of the slides and links to the documents can be found below:

2023-11-04 Current Federal Tax Developments

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This week we look at

  • Taxpayers can’t rely on paid preparer as reasonable cause for late filing, even when using electronic filing
  • IRS could assert negligence penalty (and obtain supervisory approval) after failing to obtain approval for substantial underpayment penalty
  • IRS makes “temporary” electronic signature program permanent by moving it into the Internal Revenue Manual

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

The slides and links to documents for this week’s update can be downloaded at:

2023-10-30 Current Federal Tax Developments

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This week we look at

  • PTIN renewals are now open for 2024
  • IRS announces program to allow for withdraw of ERC claims
  • Actor’s estate loses in attempt to claim he had validly rolled over a non-traditional investment held in his IRA

This week’s slides and supporting document links:

2023-10-23 Current Federal Tax Developments

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This week we look at

  • Sloppy records cost CPA the vast majority of his business deductions
  • IRS issues warning about art deduction tax promotions aimed at high-income taxpayers
  • IRS gives details on transfers of electrical vehicle credits to dealers beginning in 2024

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

The slides and links to the documents discussed can be downloaded via the link below:

2023-10-09 Current Federal Tax Developments

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This week we look at:

  • IRS reduces PTIN fees substantially
  • Wash sale rules do not apply to losses on disposition of money market funds
  • IRS highlights new capabilities added to TaxPro accounts
  • Employers can set up leave-based donation programs for 2023 Hawaii wildfire relief
  • FinCEN grants 60 additional days for entities created in 2024 to file initial reports

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

A PDF of the slides and links to supporting materials can be downloaded below:

2023-10-02 Current Federal Tax Developments

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This week we look at:

  • FinCEN provides guide to small businesses for beneficial ownership reporting under the Corporate Transparency Act
  • Taxpayer cannot rely on the mailbox rule to prove timely mailing/filing of tax return, as §7502 is the sole way of proving timely postmark and get presumption of delivery
  • Impact of receipt of a CP2100/2100A notice on backup withholding

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

A PDF with the slides and links to articles can be downloaded below:

2023-09-25 Current Federal Tax Developments

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This week we look at:

  • Just having a CPA prepare a taxpayer’s return does mean the taxpayer will get reasonable cause relief for assessments
  • IRS announces halt to processing of new ERC claims until after 2023, will slow processing of claims currently in progress

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

A PDF of this week’s slides and links to articles on the developments.

2023-09-18 Current Federal Tax Developments

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IRS finally releases guidance on TCJA changes to IRC Section 174 and a late season update to K-2/K-3 FAQ

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This week we look at:

  • HHS sends letter to DEA recommending that marijuana be reclassified as a Schedule III drug
  • General guidance issued determining tax status of 2023 state payments - and IRS asks for comments prior to giving additional guidance
  • IRS clarifies limits of 2007 CCA on ESBTs and NOLs
  • News release on electronic filing of Form 8300

The slides and this week’s article links can be downloaded below:

2023-09-05 Current Federal Tax Developments

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IRS delays effective dates for digital asset reporting and forcing catch-up contributions of high earners to be made to designated Roth contributions.

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Doctors discover the limits of the rent your home to your business tax strategy, IRS publishes memo address trust based tax shelter and more.

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Warning issued about certain ESOP plans, taxpayer cannot accelerate deduction of nonqualified deferred compensation due to sale of business and more.

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IRS rules on taxable status of staking rewards, proposes to add new listed transaction and more.

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Oversight Subcommittee of the House Ways & Means Committee holds hearing on ERC issues. IRS greatly reduces announced visits by Revenue Officers and more.

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IRS issues a memo indicating its displeasure for extended supply chain justifications for ERC, 3rd Circut decides that 90-day deadline for filing a deficiency petition is open to equitable relief and more.

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This week we look at the IRS guidance on RMDs, extending RMD relief by one year, filing date relief for victims of Vermont flooding and more.

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Research credit denied to S corporation and penalties imposed, why a request to be treated as a §501(c)(3) organization was denied and more.

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Protective claims become an issue as the Supreme Court accepts a case on the validity of 965 transition tax, IRS releases some draft 2023 partnership income tax forms and more.

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We look at issues people run into in tax research, IRS ends COVID-19 HDHP relief and more.

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OIRA will no longer review IRS regulations prior to publication, IRS releases most recent consolidated accounting method change revenue procedure and more.

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Ways and Means Chair introduces 3 tax bills, starting negotiation season for any 2023 tax bill, IRS grants relief to allow partnership to make late election not to claim bonus depreciation and more.

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This week we look at:

  • Fourth Circuit does not agree with view expressed by Seventh Circuit in Menard, Inc. that C corporation reasonable compensation only depends on a reasonable return to investors
  • Eleventh Circuit holds that “hobby loss” expenses under §183 are miscellaneous itemized deductions
  • Elderly attorney had reasonable cause for failure to file payroll tax returns and timely pay payroll tax liabilities

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

A copy of this week’s slides and links to articles can be downloaded below:

2023-06-05 Current Federal Tax Developments

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This week we look at:

  • Tax Court finds they have no authority to review the IRS notice for certification of seriously delinquent tax debt to State Department
  • IRS publishes warning signs for employers to use to identify ERC scams
  • Fourth Circuit finds that Section 7502 fully supplants common law mailbox rule for filing documents

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

The slides and links to articles for this week’s broadcast can be downloaded below:

2023-05-30 Current Federal Tax Developments

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This week we look at:

  • Supreme Court rules in favor of IRS on issue of when notice must be sent when the IRS issues a third-party summons
  • IRS agent gets distracted by small issues, fails to investigate potentially much larger one and it costs the IRS at Tax Court
  • IRS announces 2024 HSA and excepted benefit HRA inflation adjusted amounts

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

This week’s slides and links to articles can be downloaded below:

2023-05-22 Current Federal Tax Developments

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This week we look at:

  • IRS email discusses issues that arise with payroll tax refunds when a PEO is involved who itself has unpaid tax liabilities
  • Letter ruling provides that Forms 1099-C must be filed by a credit union due to writing off certain debts as part of a legal settlement
  • IRS plans to add more detail to partnership K-1 liability disclosures on 2023 returns

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

A copy of the slides with links to stories for this week’s update can be downloaded below:

2023-05-15 Current Federal Tax Developments

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This week we look at:

  • IRS issues CCA making clear how strict the §125 substantiation rules are
  • Taxpayer’s lack of documentation forces him to accept preparer’s gross gambling winnings and limits his gambling loss deduction
  • Tax Courts finds that last second rule for filing a Tax Court petition is not the same as for returns filed via eFile

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

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

2023-05-08 Current Federal Tax Developments

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This week we look at:

  • More CRAT problems - but this one the IRS had warned against using
  • Change of protocol underlying cryptocurrency from proof of work to proof of stake is not a taxable event
  • Fact some countries now treat Bitcoin as legal tender does not change its status as property, not foreign currency
  • Taxpayer finds they had to wait a year to claim a deduction for cashier’s check purchased to settle legal dispute

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

The slides and links to supporting articles can be downloaded below:

2023-05-01 Current Federal Tax Developments

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This week we look at:

  • Another taxpayer fails to establish either spouse as a real estate professional
  • SPIFF was not a separate trade or business
  • IRS releases revised Form 3115
  • IRS letter to Senator on PEOs and ERC
  • FinCEN publishes FAQ on Corporate Transparency Act reporting

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

The slides and citations for this week’s broadcast can be downloaded below:

2023-04-23 Current Federal Tax Developments

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This week we look at:

  • IRS announces non-acquiescence in Tax Court case on taxpayer asserting substance over form
  • IRS highlights bad tax advice on social media
  • IRS rules that assets held in intentionally defective grantor trust do not obtain date of death basis
  • IRS releases proposed battery regulations for new EV credits

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

The slides and citations for this week cna be downloaded below:

2023-04-03 Current Federal Tax Developments

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This week we look at:

  • IRS begins 2023’s Dirty Dozen Tax Scams with problematical ERC refund claims
  • IRS announces position on evaluating when a non-fungible token is a collectible
  • C corporation not allowed to take home office expenses for owner-employee’s home
  • IRS email reminder that BBA opt-outs must be made on original returns

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

The slides and links for this week’s broadcast can be downloaded below:

2023-03-27 Current Federal Tax Developments

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This week we look at:

  • Trust that was meant to be a CRAT found not to be one and attempted fix was too late and not undertaken correctly
  • PLR looked at whether item for consumption by infant to reduce risk of developing a condition was all or partially a medical expense
  • IRS produces FAQ on whether different types of health expenses qualify as medical expenses

The slides and links to the documents can be downloaded here:

2023-03-20 Current Federal Tax Developments

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This week we look at:

  • IRS and OPR issue separate warnings on ERC claims
  • Ninth Circuit reverses Seaview Holdings LLC decision after en banc hearing, partnership return not forwarded to Ogden was never filed
  • IRS gives financial institutions RMD notice relief
  • S corporation accidentally ended its status by revising its LLC operating agreement

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

You can download a copy of the slides with links to documents.

2023-03-13 Current Federal Tax Developments

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This week we look at:

  • Deposit and use by sheriff of jail meal money not found to be a mere misunderstanding
  • Amounts taxpayer expected to repay with future earnings found not to be loans, taxable upon receipt
  • SCOTUS rules non-willful FBAR failure is a per-form not per-account penalty
  • CPA fails to provide substantiation for deductions for practice

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

A copy of this week’s slides and links to source materials can be downloaded below:

2023-03-06 Current Federal Tax Developments

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This week we look at:

  • Proposed regulations issued for retirement plan forfeitures
  • OIRA completes review of crypto broker proposed regulations, expected to be issued shortly
  • IRS extends relief for taxpayers impacted by disasters in California, Alabama and Georgia
  • IRS issues final business electronic filing mandate regulations

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

The slides and links to the documents discussed can be downloaded below:

2023-02-27 Current Federal Tax Developments

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This week we look at

  • IRS announces program to accept upload of documents in response to some, but not all, notices to taxpayers
  • SECURE 2.0 Section 603 drafting glitch puts catch-up contributions at risk for 2024 as various parties push to get a fix
  • IRS will not automatically challenge §199A deduction for cannabis businesses-but W-2 wage problems may get in the way

A copy of the slides and links to related material can be downloaded below:

2023-02-20 Current Federal Tax Developments

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This week we look at:

  • IRS relents to pressure, releases guidance on state payment programs’ taxability (generally it’s good news)
  • IRS begins offering direct deposit for Form 1040-X electronic filers - but it will still take a long time to process
  • No substantive §174 guidance likely before initial tax deadlines (March & April)
  • Form 4868 didn’t qualify as informal claim for refund

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

A copy of the slides with links to source materials can be downloaded below:

2023-02-13 Current Federal Tax Developments

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This week we look at:

  • IRS revises classification of clean vehicles for purposes of determining vehicles subject to $80,000 MSRP limit
  • Proposed revenue procedure published to establish new voluntary tip reporting procedure
  • Taxpayer’s log of every mile of vehicle use had issues that prevented Tax Court from accepting it for meeting burden under IRC §274(d)

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

A PDF of the slides for this week’s update can be downloaded below;

2023-02-06 Current Federal Tax Developments

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This week we look at:

  • IRS begins accepting 2022 income tax returns
  • IRS opens up IRIS portal for electronic filing of information returns
  • Corporation forced to get private letter ruling on S election due to failure to obtain all required consents

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

The slides for this week’s session can be downloaded as a PDF below:

2023-01-30 Current Federal Tax Developments

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This week we look at:

  • IRS provides an extended due date for some in Alabama and Georgia impacted by storms
  • IRS announces 10 minute response time on Practitioner Priority Line
  • Taxpayer’s §401(k) distribution not excluded from income based on diabetes diagnosis
  • IRS releases auto depreciation limits under §280F for 2023

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

Audio Block Double-click here to upload or link to a .mp3. Learn more Articles for this week’s update can be downloaded as a PDF below:

2023-01-23 Current Federal Tax Developments

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This week we look at:

  • IRS begins accepting returns on January 23
  • California taxpayers get due dates delayed until May 15
  • Amended return research credit additional information requirements added to draft Form 6765 instructions
  • Employer provided housing not excluded from income under §119
  • No loss allowed on not quite worthless not really stablecoin
  • Appraisals required for donation of cryptocurrency

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

A PDF with this week’s articles can be downloaded below:

2023-01-16 Current Federal Tax Developments

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This week we look at issues that arise with S corporations.

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

You can download the write-up of the Twitter thread that drove this week’s program here:

Why Aren’t S Corporations Perfect for All Clients and Situations?

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Congress passed the SECURE 2.0 Act of 2022 that was signed into law on December 29, 2022. This program gives a brief overview of the provisions of this Act that will help tax professionals advise their clients about the impacts and opportunities found in this law.

A summary of the SECURE 2.0 Act of 2022 can be downloaded below:

SECURE 2.0 Act of 2022 Summary

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This week we look at:

  • IRS to issue regulations for definitions for new clean vehicle credit
  • List published on IRS website to assist in determining if a vehicle could qualify for new clean vehicle credit
  • Incremental cost safe harbors for §45W commercial clean vehicle credit issued by IRS
  • 2023 mileage rates release
  • Final 2022 Schedule K-2 and K-3 Form 1065 instructions released

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

A PDF with articles for this week’s updates can be dowloaded below:

2023-01-03 Current Federal Tax Developments

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This week we look at:

  • Congress passes spending bill which included SECURE 2.0 Act of 2022
  • Final Schedules K-2 and K-3 instructions issued for Form 1120S
  • IRS delays digital asset reporting until regulations are issued
  • Expanded Form 1099-K reporting delayed for one year by the IRS

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

Articles on this week’s update can be downloaded as a PDF below:

2022-12-27 Current Federal Tax Developments

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This week we look at:

  • IRS memorandum looks at marketed program to defer recognition of legal fees
  • Automatic change of accounting method procedure released by the IRS
  • IRS publishes news release on upcoming FICA/SE tax 2020 deferral payment due date

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

A PDF with this week’s update articles can be downloaded below:

2022-12-19 Current Federal Tax Developments

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This week we look at:

  • IRS releases second draft of instructions for preparing 2022 Schedules K-2 and K-3 for partnerships and S corporations
  • IRS begins issuing proposed regulations to deal with court losses on method used to add listed transactions not following the Administrative Procedures Act

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

A PDF with this week’s articles can be downloaded below:

  • 2022-12-12 Current Federal Tax Developments

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This week we look at:

  • IRA 2022 prevailing wage and apprenticeship requirement guidance issued by the IRS
  • Taxpayers denied partnership loss due to a large number of issues, many of which were enough standing alone to deny the loss entirely

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

A PDF with articles for this week’s developments can be downloaded below:

2022-12-05 Current Federal Tax Developments

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Taxpayer's damages settlement was taxable income, a refund suit is filed too early and amending an LLC operating agreement accidentally terminated S corporation status.

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IRS issues news releases on qualified charitable distributions from IRAs and on upcoming Seventh Annual National Tax Security Awareness Week.

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Tax Court finds IRS must follow Administrative Procedures Act when added to listed transaction list for §6707A, speculation on the impact of the election on lame duck session tax matters and tax issues for next year.

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IRS releases draft 2022 Form 1120S Schedule K-2 and K-3 instructions, taxpayer discovers tax benefits alone don't equate to a profit motive and more.

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The IRS opens up 2023 PTIN renewals and releases draft partnership K-2 and K-3 instructions with revised exceptions to filing.

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IRS announces and begins pilot program to block automated calling systems and inflation adjusted 2023 numbers released.

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IRS gives relief for certain required minimum distributions found in SECURE Act proposed regulations, major S corporation relief procedure issued and more.

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FinCEN finalizes beneficial owner reporting rules that will apply in 2024, Hurricane Ian filing relief issued and more.

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IRS releases two news releases emphasizing guidance we discussed in recent weeks.

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This week we see the IRS issue guidance on taxation of a borrower who receives PPP loan forgiveness the borrower did not deserve and the AICPA adds more requests for expansion of penalty relief.

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EARN Act sent to the Senate floor, IRS accidentally posts Form 990-T data that was not required to be revealed, and a taxpayer is denied reasonable cause relief.

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AICPA issues proposed revisions to Statements on Standards for Tax Services along with comments to the IRS on additional K-2 and K-3 guidance and request for more time to file returns qualifying for Notice 2022-36 late filing relief.

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IRS releases significant penalty relief, National Taxpayer Advocate adds more context and more this week.

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This week we look at the release of list of electric cars with final assembly in North America, IRS guidance on plug in vehicle credit for remainder of 2022 and more.

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We look at some key provisions for CPAs working with individuals and non-public companies in the Inflation Reduction Act of 2022.

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This week we look at where we are on the IRA 2022 bill, a costly divorce decision for the payor and more.

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Yet again we have a reconciliation bill. Will this one pass and what is in it that impacts taxes? Taxpayer needs to file 2020 Form 1040 if IRS failed to send economic impact payment and IRS warns on two security issues impacting tax professionals.

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TAM rules on impact on the 5/10 material participation rule of prior year qualification under SPA test, accountant's spouse denied innocent spouse relief and more.

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Reconciliation bill discussions break down, taxpayer denied charitable contribution and more.

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IRS extends automatic portability election relief to five years, talks start again on reconciliation bill and more.

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TAS begins accepting referrals from Congressional offices on 2021 and earlier returns, Fifth Circuit holds substantial compliance does not apply to provisions set by statute, etc.

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IRS and National Taxpayer Advocate release information on paper return processing, Supreme Court to take on FBAR penalty case and more

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Innocent spouse relief ruled not available for payroll tax matters, when are clothes a business expense and more.

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IRS revises mileage rates mid-year and a taxpayer is denied relief from failing to file Form 3115

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AICPA sends letter to IRS on guidance for §174 amortization; a discussion of basis issues for S corporations

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Taxpayer discovers her documentation is inadequate for her charitable contribution and IRS rules a retail drug business can be a qualified §1202 trade or business.

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A physician's payments to a former spouse were not alimony for tax purposes, IRS extends remote plan document signing, and more.

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Taxpayer argues return given to IRS agent at agent's request begins running of the statute, IRS destroys 30 million information return, and more.

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S corporation has to apply for PLR due to failure to follow trust document, first inflation adjusted numbers for the year, and more.

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Issues with the special for military disability benefits and retirement pay, IRS pushes back date for electronic filing of S corporation Schedules K-2 and K-3 and more

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A discussion of the no-additional cost employee fringe benefits, the IRS adds more Q&As to the K-2/K-3 FAQ, and more.

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The House passes a new retirement plan reform bill, IRS suspends more notices and more.

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IRS gives information on taxation of crowdfunding fact sheet, Ninth Circuit agrees with Tax Court that legal award was taxable and more.

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IRS releases 2022 auto depreciation numbers, guidance for farmers and fisherman on underpayment penalty relief finalized and more.

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Department of Labor cautions 401(k) plan fiduciaries about offering digital asset investment options, corporation fails to obtain a deduction as expense found to be personal and more.

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IRS grants relief to farmers and fisherman due to tax software issues, Justice Department files motion to dismiss staking case and more.

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Taxpayers discover they get no penalty relief for a data entry error, new proposed regulations for required minimum distributions and more K2/K3 issues.

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The IRS's special 2021 tax return relief for filing Schedules K-2 and K-3 are the big issue for this week. We look at the general rule that existed before, and the special 2021 rule that may allow more partnerships and S corporations to avoid preparing these Schedules.

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The IRS suspends the issuance of more notice types to attempt to catch up on the growing backlog, LB&I starts a new partner basis campaign and more.

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Continuing the discussion of K-2/K-3 issue and news on upcoming upgrades to TaxPros accounts.

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The IRS updates instructions for Schedules K-2 and K-3 and we look at IRS notices issues and actions.

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IRS update substantially equal payments guidance, finalizes Form 7203 and issues guidance via instructions.

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IRS sees increasing pressure to grant some form of relief on penalties and notices, IRS announces start of tax season on January 24 and more.

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IRS addresses how to treat expenses used to obtain PPP forgiveness in computing S corporation AAA, IRS publishes IRM changes to implement change in handling research credit refund claims and more.

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The IRS quietly changes web guidance on Ida relief, a valuation issue discussed in IRS memorandum and more.

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IRS and Malta issue guidance to shut down tax shelter, Hurricane Ida relief date pushed back to February 15 and more.

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Congress leaves town without passing BBBA, Senator Manchin announces he's a no vote on the bill, the IRS releases the 2022 mileages rates and more.

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IRS released fourth quarter ERC guidance, a case involving community property and taxation in the year of a divorce and more.

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IRS issues two email responses on BBA issues and a spouse found to have tacitly agreed to joint return filing on a return she didn't sign.

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First informal guidance published by the IRS on the repeal of the ERC for the fourth quarter for most employers, agents to be trained to examine ERC and more.

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A taxpayer runs into issues with her self-directed IRAs, the IRS releases guidance on the timing of PPP loan forgiveness and more.

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IRS releases inflation adjusted numbers for 2020, TAS announces it won't give assistance on delayed processing of amended returns that have no other issues and more.

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We look at the tax provisions of the Infrastructure Investment and Jobs Act, as well as the IRS release of inflation adjusted retirement plan numbers for 2022.

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A first look at the draft version of the Buy Back Better Act that was released this week, looking at what items are no longer part of the bill and key items in the bill.

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IRS releases official draft of S corporation basis form for 2021 Forms 1040, provides some qualified plan guidance for rehiring employees and more.

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Congress continues to negotiate new tax bill, IRS notes the limits of FAQs and more.

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The Tax Court discusses the proper place to deduct hobby loss expenses on a tax return, the IRS to impose a fee for estate tax closing letters and more

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A taxpayer had a number of issues in Tax Court and a buy-sell agreement did not control the value of shares for estate tax purposes.

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Ways and Means completes mark-up of tax bill, taxpayer finds entire amount of legal settlement taxable and taxpayer has reasonable basis to avoid penalties

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Looking at if an amended return is required, IRS updates special per diem rates and gives information on W-2 COVID leave information to be reported for 2021.

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The IRS makes previously temporary e-Signature options permanent and we discuss the role of "unambiguous" text in interpreting the IRC in view of SCOTUS directive in Connecticut National Bank on interpreting law.

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A taxpayer spending money to look for a trade or business is not in a trade or business and the IRS issues a PMTA that finds the law requires a hefty penalty for employers that don't timely pay deferred employer FICA taxes under the CARES Act.

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A taxpayer failed to show loss resulted from 1244 stock and a look at the state passthrough entity taxes

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IRS gives additional guidance on ERC gross receipts test, depreciation limits announced and yet again we have a case involving timely filing decided in the courts.

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IRS releases more guidance on ERC, including key problem with claiming the credit on wages of majority owner and spouse and more.

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SBA makes modifications to PPP loan forgiveness process, IRS expands employer paid leave credit to cover more vaccination related leave and more.

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IRS asks for comments on proposed basis reporting form to be filed with Form 1040 for S corporation shareholders, a taxpayer is unsuccessful in asserting the Cohan doctrine, and more.

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Digitally signed return found not to be properly submitted, AICPA confirms PPP pre-forgiveness necessity inquiries by SBA to end and more.

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The IRS releases a batch of information letters covering various topics, an IRS agent runs into tax home problems and other developments.

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The Supreme Court refuses to hear a case regarding state taxation of remote employees, the IRS publishes draft instructions for new Forms K-2 and K-3 along with penalty relief procedure and more.

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SBA reportedly dropping the PPP loan necessity questionnaire for large borrowers, IRS extends remote witnessing rules for certain qualified plan documents and more.

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Supreme Court again upholds the ACA-or decides not to decide if it should be upheld. The IRS also releases guidance due to the backlog of unprocessed returns.

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A taxpayer discovers the legal settlement she received is taxable, the IRS discusses the 2021 child and dependent care credit and more.

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The Senate Parliamentarian changes the odds for a major law change passing soon, long time CPA gets hit with his own FBAR penalties and more.

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Green Book gives us an effective date for the proposed change in capital gains, more information on the unemployment exclusion in community property states.

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IRS releases 41 pages of questions and answers on COBRA Premium Assistance Program and

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The IRS aims for July to roll out more advanced POA submission portal, HSA numbers for 2022 released and more.

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The IRS sends John Doe summons to Kraken cryptocurrency exchange, IRS discusses aircraft and sole proprietors and more

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IRS looks at the unemployment exclusion and community property states, the While House publishes a fact sheet on their most recent tax proposal and more.

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The IRS extends special rule for accepting electronic and digital signatures, the agency acknowledges issues with April 15 MeF payments and more.

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Alimony issues still are relevant for many taxpayers, the IRS discusses deductible medical costs and more

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We look at what will happen to 2020 Form 1040 overpayments applied to 2021 taxes for underpayment penalty purposes, the IRS defines what is a restaurant and more.

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A look at the odd situation under §51(i)(1) and the employee retention credit, plus additional IRS guidance issued this week.

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IRS quietly updates how to calculation modified adjusted gross income for ARPA unemployment exclusion, PPP loan program extended and more.

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IRS finally relents and extends the tax deadline for Form 1040s only to May 17, but keeps 1st estimate for 2021 due on April 15, as well as other developments

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Congress has passed and the President has signed into law the American Rescue Plan Act of 2021 which we look at this week in summary.

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The IRS finally releases guidance on how the 2020 revised employee retention credit interacts with PPP loan forgiveness applications, gives more guidance on virtual currency question on Form 1040 and more.

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The House passes a new tax bill, late changes are made to the PPP loan program again.

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§280E bars more than just §162 deductions, taxpayer cannot claim legal malpractice award as being related to physical injury, calls come to push back filing deadline and more.

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Taxpayer fails to get FBAR penalty relief, Tax Courts outlines when it will allow a taxpayer to argue substance over form, and IRS warns about a phishing scam.

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Form 1040 instructions add to the confusion over virtual currency question on return, IRS orders banks to issue corrected Forms 1099 for SBA loan payments and more.

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IRS gives advice to victims of unemployment compensated related identity theft, a revised Form 7200 released in draft form that indicates how employers will claim the advance employee retention credit and more.

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The IRS releases first guidance on revised 2020 ERC program, limited penalty relief provided for tax basis capital reporting on partners' K-1s, and a lot of SBA guidance on the PPP loan programs as revised by the CAA.

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The IRS delays the acceptance of returns until February 12, the IP-PIN voluntary program opens up nationwide and more.

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This week we look at the two IFRs issued by the Small Business Administration for the revised PPP loan program.

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IRS finalizes accounting method regulations, proposes a user fee for estate tax closing letters, an email explains the statute of limitations and the added time to file 2019 returns, and more.

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A summary of employee retention credits found in the Consolidated Appropriation Act, 2021, a bill that is currently in limbo as the President has threatened not to sign the bill without specific changes.

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The pieces of the proposed PPP provisions in the COVID-19 relief bill being negotiated by Congress for potential passage.

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SBA indicates that §1112 payments made by SBA on §7(a) loans will be taxable to recipients, IRA gives some guidance on two CARES plan provisions, and more activity.

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IRS security week brings announcement of expansion of opt-in IP PIN program nationwide and advice to make use of multi-factor authentication and more

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A taxpayer finds that the IRS does not generally give relief for late filed elections under IRC §475(f) as well the release of two sets of final regulations.

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IRS releases guidance for borrowers who have not received forgiveness by year end, more information will be requested on 2020 Form 1120-S Schedule K-1, and more.

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IRS may be about to releases additional guidance on deducting expenses paid with PPP funds, IRS concedes that entity level tax SALT workarounds work and more.

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IRS issues revised tables for computing RMDs effective in 2022, a taxpayer discovers believing your CPA filed an extension is not reasonable cause for late filing and more.

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The SBA announces questionnaires for large PPP borrowers and an unconfirmed copy is distributed online, the IRS gives instructions on preparing W2s for employers that deferred employee FICA from September 1 and more

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IRS releases draft Form 1065 that indicates tax basis capital account will be required on 2020 K-1s, FBAR returns get a short extension of time to file and more.

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SBA clarifies the deadline to apply for forgiveness, IRS quietly changes view on the computation of QBI, and more.

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The SBA issues new guidance, including a simplified forgiveness form for borrowers with loans of $50,000 or less, the IRS begins using QR codes on notices and more

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The SBA outlines the issues that arise with a change in ownership with a PPP loan outstanding and the IRS finalizes two sets of regulations.

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IRS issues final regulations on excess deductions on depreciation and bonus depreciation, as well as relief for the CCH e-file problems from September 15.

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The IRS publishes new draft for self-employed to claim FFCRA sick pay credits, updates the Form 941-x to allow revising second quarter and more.

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IRS issues guidance on the SECURE Act retirement provisions, Tax Court finds an IP PIN is not part of a signature for electronic filing and more.

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The IRS outlines information on a number of retirement plan changes adopted at the end of 2019, a minister learns a hard lesson about payroll tax rules for ministers and churches and more.

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IRS issues payroll tax holiday guidance late on Friday afternoon, the SBA adds more PPP loan program guidance and more.

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US Chamber of Commerce sends letter with issues on payroll tax holiday and Chair of Ways & Means asks IRS to slow down sending notices until the mail backlog is under control, and more.

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Taxpayer finds out the IRS won't waive the 60-day rollover period when they "borrow" money from their IRA to make a cash offer on a home and more.

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Employee OASDI taxes to be deferred beginning September 1, but forgiveness is an unknown for now, SBA issues a PPP loan forgiveness FAQ and more.

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The IRS finishes three regulation projects, with some key guidance in the small business accounting method proposed regulations. Also, the IRS announces Form 3115 for automatic changes will be received by fax for now.

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A taxpayers comes before the Tax Court for the third time on yet another issue--and again ends up with a loss. As well, the SBA indicates when it will begin accepting information from lenders to approve PPP loan forgiveness.

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Two cases look at cancellation of debt issues in the Tax Court this week, the IRS sets PTIN fees to restart for next tax season and more.

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IRS publishes a flowchart outlining BBA partnership audit process, Congress extends PPP loan program through August 8, and more

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IRS described issues with marketing materials for CRAT shelter, a discussion of superseded returns and more.

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CARES Act guidance on returning distributions taken before 2020 RMD relief enacted in CARES Act, the parking lot tax gets more guidance and more.

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Revised PPP forgiveness applications and rules issued by the SBA, CARES retirement plan rules guidance issued and more

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IRS issues new proposed regulations on post-TCJA like kind exchanges, SBA issues first formal PPPFA guidance and more.

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Congress revises the Paycheck Protection Program loans in legislation signed into law this week, IRS grants physical presence relief for plans and revisits tax basis capital issues for partnerships.

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New PPP bill come up in Congress, IRS announces electronic filing coming up for amended returns and other developments.

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The latest update on the new interim final regulations on PPP Loan Forgiveness rules.

A PDF with information on both IFRS can be downloaded below.

May 22 IFRs from SBA - PPP Loan Forgiveness

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This week we look at:

  • PPP guidance on foreign affiliates, §501(c)(12) utilities, the actual final extension of the PPP repayment date and the SBA backing off the threats on necessity of the loan certification
  • IRS discusses which date to use to value certain stock based compensation
  • Changes made to maximum medical FSA carryovers for cafeteria plans
  • IRS issues COVID-19 related relief for cafeteria plans
  • The tax consequences of payments to students discussed in IRS FAQ which uses §139 to exclude them from income
  • IRS releases inflation adjusted HSA and HDHP numbers for 2021

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

A PDF with the articles related to this week’s updates can be downloaded below:

2020-05-25 Current Federal Tax Developments

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This week we look at the SBA's release of the PPP Loan Forgiveness Application and related instructions from Friday, May, 15.

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

Below is a document looking at the application form and instructions.

2020-05-18 PPP Loan Forgiveness Application: What Have We Learned?

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This week we look at:

  • IRS changes its guidance on the payment of health insurance only and qualification for the Employee Retention Credit
  • Borrowers can repay PPP loans by May 14 and then use Employee Retention Credit in the future.
  • SBA issues guidance for non-discrimination rules and not for profits and also impact of student workers.
  • Borrowers using new seasonal employer measuring periods will be able to sign unmodified PPP loan applications.
  • SBA gives relief to businesses unable to rehire employees who wish to remain on unemployment.
  • IRS issues guidance on excess deductions on termination following TCJA's addition of §67(g).
  • Taxwriters disagree with IRS's view on deductibility of expenses used to obtain PPP loan forgiveness.
  • Cannabis business found to be a reseller and not a producer. IRS issues guidance on taxpayers whom the agency wishes to return their economic impact payments.

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

Articles for this week’s developments can be downloaded via the link below:

2020-05-11 Current Federal Tax Developments

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This week we look at:

  • PPP loan updates on corporate groups, businesses sold after February 15, 2020, loan review procedures, private companies need to show loan was necessary, treatment of seasonal employers, how to count 500 employees and maximum loan calculation amounts
  • Update on faxing procedures for Forms 1139 and 1045
  • No deduction allowed for amounts paid to achieve PPP loan forgiveness per IRS
  • Draft Form 941 released for second quarter of 2020
  • IRS clarifies filing date relief for U.S. Tax Court filings
  • IRS and DOL issue relief for certain timeframes that apply to employee benefit plans

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

Articles for this week’s session are available for download below:

2020-05-04 Current Federal Tax Developments

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This week we look at:

  • PPP Loan program and EIDL Grants Get Additional Funding
  • PPP guidance raises question of false certification that loans were necessary, provides other clarifications
  • IRS provides additional guidance on payments to repair homes due to pyrrhotite damage
  • Relief for taxpayers unable to meet foreign earned income exclusions due to COVID-19
  • Special procedures for taxpayers who are not required to file but wish to file for advance payments
  • IRS gives special relief related to COVID-19 travel restrictions impacting substantial presence test

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

A PDF with the articles for this week can be downloaded below:

2020-04-27 Current Federal Tax Developments

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This week we look at:

  • SBA issues guidance on self-employed taxpayers and partners for PPP loan program
  • Revenue Procedure issued explaining how to deal with retroactive change in life for qualified improvement property
  • IRS gives guidance on filing Forms 1139 and 1045 via fax while Service Centers are shut down
  • Proposed regulations released to set government portion of PTIN fee at $21
  • Procedures issued to deal with Forms 706 returned by private delivery services from closed Service Centers

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

Articles for this week’s updates can be read below:

2020-04-20 Current Federal Tax Developments

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This week we look at:

  • PPP loan program FAQ gets updated by SBA
  • IRS releases §163(j) relief for real estate and farming businesses
  • Procedures released for making election to waive NOL carryback period under CARES provisions
  • IRS explains the payroll tax deferral program
  • Partnerships covered by BBA CPAR given temporary reprieve from centralized audit rules
  • Six month extension granted to file Forms 1045 and 1139
  • IRS greatly expands list of returns, payments and actions extended to July 15, 2020.

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

The articles for this week’s updates can be found in the PDF you can download below:

2020-04-13 Current Federal Tax Developments

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This week review the status of developing guidance on key provisions of the CARES Act:

  • Recovery Rebate for Individuals, Including Advance Payment
  • Deferral of the Required Minimum Distributions for 2020
  • PPP SBA loan program - things we've learned and things we still need guidance on
  • Forgiveness of PPP loans - are payroll costs different for this than for the maximum loan or not? Does anyone know for sure?
  • Emergency EIDL Loans - the forgotten provision Employee retention payroll credit - the alternative (maybe) to a PPP loan
  • Delay of deposits for employer portion of OASDI taxes - can take if you don't have a PPP loan forgiven

An audio only version of this week’s podcast can be streamed or downloaded at:

This week rather than written text, we are including a PDF of the slides that go along with this week’s presentation:

2020-04-06 Current Federal Tax Developments Slides

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This week we look at:

  • Payroll tax credit starts on April 1.
  • IRS reverses courses, announces gift/GSTT returns will also be due on July 15, 2020.
  • IRS issues guidance that clarifies which April 15 deadlines are moved back to July 15, 2020.
  • Congress passes the CARES Act with a number of tax provisions

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

Articles for this week’s update can be downloaded from:

2020-03-30 Current Federal Tax Developments

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This week we look at:

  • Congress passes payroll tax credit for newly mandated paid sick leave
  • Initial April 15 delay guidance only delayed payment date but no actual extension to file
  • Late Friday guidance replaces first delay guidance with a real delay in April 15 filing date, though questions still remain

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

A PDF with articles for this week’s developments can be downloaded below:

2020-03-23 Current Federal Tax Developments

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Current Federal Tax Developments for the week of March 16, 2020: Waiting for Relief

  • President declares emergency over COVID-19, directs Treasury to provide relief--and now we are waiting.
  • HR 6201 passes the House and moves on to the Senate, containing a few tax provisions mainly related to mandatory sick leave provision rule
  • AICPA letter issued to IRS regarding the informal §199A guidance the agency has issued
  • HDHPs are allowed to pay for COVID-19 testing and treatment without jeopardizing ability of insured to make HSA contributions.
  • Dropping a tax document in the mailbox turns out not to be a good idea, as USPS postmark was after the private postmark date on envelope

Articles for this week’s final three developments can be found in the following PDF file:

2020-03-16 Current Federal Tax Developments