Current Federal Tax Developments

This week we look at:Transitioning Foreign Tax Allocations and Implementing the Ten Percent Credit Disallowance Under Section 960(d)(4)Trustee-to-Trustee Transfers of Inherited IRAs Through an Estate: Technical Analysis of PLR 202631001Federal Courts Lack APA Jurisdiction Over Foreign Gift Penalty Disputes: The Adequate Alternative Remedy BarrierSourcing Executive Termination Payments: Analyzing the Bifurcated Sourcing of Severance and RSUs in the Appeal of OttingThe Permanent Section 45S Paid Family and Medical Leave Credit: Analyzing the Statutory Wage Method Mechanics and the New Premium Method Under Notice 2026-28The Tax Court Open Door: Why the BBA Partnership Petition Deadline Is Not JurisdictionalCommingled Funds, Unsubstantiated Deductions, and the Binding Form of Transactions: A Technical Tax Analysis of Reed v. CommissionerThe Safe Harbor That Wasn't: Deconstructing the Anti-Abuse Rule in SIH Partners LLLP v. CommissionerThe Evolution of Qualified Overtime Compensation Deductions: Analyzing IRS Fact Sheet FS-2026-13 and Its Practical ImplicationsAn audio only version of this week's broadcast can be streamed or downloaded below: 2026-08-10 IRS Guidance on Qualified Overtime for 2026-2028 Edward K. Zollars, CPA (Arizona) Download This week's articles can be downloaded below:2026-08-10 Current Federal Tax Developments

This week we look at:IRS Reinstates Tax Deferral on Variable Annuity Term Certain Options: Reconsideration and Reversal in PLR 202630002Understanding the ERC Pleading Standard: Federal Claims Court Deferral in I Health and Life Insurance ServicesPredecessor Losses, the Lonely Parent Rule, and the Limits of Economic Reality: Analysis of HBM Holdings Co. v. CommissionerDouble Books and Disguised Payees: Corporate Personal Expenses and the Civil Fraud Penalty in Prezioso v. CommissionerAn audio only version of this week's broadcast can be streamed or downloaded below: 2026-08-03 On Again Off Again On Again PLR Edward K. Zollars, CPA (Arizona) Download The articles for this week's update can be downloaded as a PDF below:Current Federal Tax Developments August 3, 2026

This week we look at: Valuation of Remainder Interest Gifts Upon Trust Termination: State Law and Net Gift Adjustments in Lewis v. Commissioner Revenue Procedure 2026-26: Technical Overview of 2027 Indexing Adjustments for Premium Tax Credits and Affordability Standards Limitations of Interest Abatement Claims Under I.R.C. § 6404(e)(1) in the Context of ERC-Driven Amendments Section 6015(c) Relief and the Substantiation Trap: An Analysis of Anderson v. Commissioner Navigating the AICPA's New Tax Services Independence Standards: A Guide for PractitionersAn audio only version of this week's broadcast can be downloaded or streamed below: 2026-07-27 AICPA New Interpretation on Independence and Tax Engagements Edward K. Zollars, CPA (Arizona) Download Articles on each update and a copy of the slides for this week can be downloaded as a PDF below:Current Federal Tax Developments July 27, 2026 ArticlesPresentation Slides

This week we look at: Partnership Recourse Rules: Conditional DROs will not establish EROL under § 1.752-2. Mileage Rate Adjustment: Business standard mileage rate rises to 76 cents on July 1, 2026. Business Tax Account: Modernized self-service portal expands features but requires active annual maintenance. Litigation Legal Fees: FCRA settlements are taxable gross income without above-the-line deduction. Corporate Reorganizations: Tax Court invalidates regulation limiting 100% DRD in post-Loper Bright era. ERC Litigation Realities: Exhaustion loophole rejected; notice pleading standards approved in refund suits. Conservation Easements: Valuation must be grounded in immediate local market demand, not speculation.An audio only version of this week's broadcast can be streamed or downloaded below. 2026-07-20 IRS Expands Business Tax Accounts Edward K. Zollars, CPA (Arizona) Download You can download a PDF with articles for this week's update and a copy of this week's slides.Current Federal Tax Developments July 20, 2026Slides

This week we look at: Transitioning from First Time Abate (FTA) to Automatic Exemption from Penalty (AEP) Strict Enforcement of Tax Refund Statutes of Limitations Employee Retention Credit (ERC) Refund Claims & Pleading Standards Pandemic-Era Persistence of New York's Convenience of the Employer Rule Invalidity of Treasury Regulation Section 1.951A-2(c)(5) Non-Shareholder Capital Contributions vs. Compensation Final Section 1035 Exchange & Corporate Reorganization Regulations Reclassification of Abusive CRAT Structures as Listed Transactions The National Taxpayer Advocate's Perspective on AEPAn audio only version of this week's broadcast can be downloaded or streamed below. 2026-07-13 A Week of Final Regulations Edward K. Zollars, CPA (Arizona) Download PDFs of the articles for this week's update and the slides can be downloaded below:2026-07-13 Current Federal Tax DevelopmentsSlides

This week we look at:Relief from Ineffective S Corporation and QSub ElectionsProcedural and Jurisdictional Limits in Challenging IRS GuidanceMedicaid Gross Receipts, Cohan Estimations, and Professional RelianceStandards and Deceit in Supervised ReleaseTransitional Guidance on Qualified Opportunity ZonesAn audio version of this week's broadcast can be downloaded or streamed below: 2026-06-22 Qualified Opportunity Zone Interim Guidance for OBBBA Edward K. Zollars, CPA (Arizona) Download Articles for this week's broadcast and copies of slides can be downloaded below:Current Federal Tax Developments June 22, 2026Slides June 22, 2026

This week we look at:Section 7508A(d) and Interest on Pre-COVID-19 Disaster Tax DeficienciesThe Soroban Capital Partners SECA Tax ControversyPleading Requirements for the Employee Retention Credit (Tapestry Senior Housing)ERC Causation and the Essential Business Hurdle (RAAM Construction)The Section 530A Transfer Tax Safe Harbor (Rev. Proc. 2026-25)Penalty Supervisory Approval Verification in CDP (Besicorp Group)Retroactive ERC Deadlines & Constitutional ChallengesAn audio only version of this week's broadcast can be streamed or downloaded below: 2026-07-06 ERC Cases Galore Week Edward K. Zollars, CPA (Arizona) Download You can download a copy of the stories for this week's updates and the slides for this week from the link below:Current Federal Tax Developments July 6, 2026 ArticlesJuly 6, 2026 Slides

This week we look at;Nominal S Corporation Ownership and the Abuse ExceptionRecapping the ERC via Section 7405 Civil ActionsConstructive Dividends, Formalities, and Civil FraudCDP Hearings, Offer-In-Compromise, and RCP CalculationsProfessional Responsibility and Responsible AI UseRigorous Proof for ERC "Partial Suspension" ClaimsAn audio only version of this week's broadcast can be downloaded or streamed below. 2026-06-29 OPR Releases Guidance on Use of Generative AI Edward K. Zollars, CPA (Arizona) Download PDFs with this week's articles on the updates and the slides used for this week's presentation can be downloaded below.Current Development ArticlesSlides for Presentation

A discussion of the impact of new Section 68 on trusts and the JCT's Blue Book Footnote 102, IRS previews upcoming Section 25F credit guidance and more.

Two decisions on the ERC and what is a partial suspension completely disagree on the level of causation that must be shown related to a government order, yet another conservation easement taxpayer loss and more.

This week we look at: Procedural Timeliness & Automatic Extensions Spousal IRA Rollovers Through Estates and Trusts Collateral Estoppel and the "Innocent" Spouse Improper Corporate Deductions and Fraud Implementation of "Trump Accounts" 2027 Inflation Adjustments (HSA, HRA, DPCSA)An audio only version of this week's update can be streamed or downloaded below. 2026-06-01 More Details on the Activation of Trump Accounts Edward K. Zollars, CPA (Arizona) Download PDFs with the slides and this week's articles can be downloaded via the links below:2026-06-01 Current Federal Tax DevelopmentsSlides

IRS (barely) acquiesces in case of Abdo but will appeal Kwong, House passes an bill to reverse Supreme Court's Zuch decision and more.

Failure to follow CWA rules eliminate all of a charitable contribution deduction, IRS announces syndicated conservation easement settlement initiative, and more.

Yet another syndicated conservation easement taxpayer loss in Tax Court, the FTB loses an attempt to tax an out of state physician and more.

Treasury and IRS previews medical marijuana Section 280E guidance upcoming, the House passes 9 bipartisan tax bills, ERC statute of limitations extension guidance for refund claims and more

DEA rescthedules state-legal medical marijuana, but recreational cannabis stays on Schedule III (and 280E issues continue for those businesses), Seventh Circuit finds claim of right can be used to exclude income from taxation and more.

IRS releases final regulations on qualified tip income, taxpayer finds that getting no cash from a surrendered life insurance policy doesn't necessarily mean no tax issues and more.

Claim of right issue dooms ability to offset repayment of social security benefits, ERC litigant loses case on appeal and more.

IRS issues proposed regulations on Trump Account and the pilot program and the Tax Court looks it issues with an IRS notice in a BBA case.

Two cases outline failed attempts to attempt to remove the block on access to their passports, auto depreciation limits for 2026 and more.

Another Circuit rules that the IRS does have the authority to assess §6038(b) penalties, delay announced in effective date for SECURE 2.0 RMD regulations and more.

Supreme Court overturns tariffs, IRS released interim guidance on Section 168(n) 100% bonus depreciation for qualified production property and more.

Attorney called out for suspected AI hallucinated cases by the Tax Court, First Circuit may be considering a method to avoid ruling on SE status or limited partners and more.

A lesson in making sure your beneficiaries are updated in ERISA covered plans following a divorce, the iRS issues guidance attacking a Charitable LLC shelter and more.

IRS issues guidance on tax refunds notices for taxpayers who don't provide bank account information, taxpayers successfully overcome presumption of delivery of a Notice of Deficiency and more.

ERC suit allowed to move forward without having a specific government order identified in filing but APA challenges thrown out, the IRS issues an FAQ on the OBBBA overtime deduction and more.

Fifth Circuit throws out functional test on self-employment income for a limited partner, IRS restarts group tax exemption process and more.

IRS announces January 26 as the start date for electronic filing for individual returns, IRS found to make a procedural error in a premium tax credit case and more.

IRS releases proposed regulations on vehicle interest, standard mileage rates for 2026 published and more.

Marijuana rescheduling proposed regulation finalization moves back into the fast lane after a year, which would remove §280E as an issue for cannabis businesses and two update Fact Sheets for OBBBA changes.

IRS releases initial guidance on Scholarship Granting Organizations (SGO) in preparation for 2027 tax credits, OICs and cannabis businesses and more.

USPS issues rules on when postmarks are applied that may make it more likely for items to be tagged as late filed, guidance on OB3 HSA expansion and more.

IRS publishes preliminary guidance on Trump Accounts and the tax credit for Scholarship Granting Organizations (SGOs).

IRS discusses future guidance on federal scholarship tax credit, Tax Court deals a loss to another syndicated conservation easement and more.

IRS releases guidance for recipients of qualfiied tips and qualified overtime for 2025 Forms 1040, Medicare numbers for 2025 released and more.

This week we look at:Annual Adjustments to Retirement Plan LimitationsEnsuring Investment Trust Status for Digital Asset Staking EntitiesExamining Penalties in Microcaptive TransactionsOwnership Requirements for Non-Business Theft LossesDefining the Scope of I.R.C. § 172(b)(3) Carryback WaiversYou can stream or download this week's audio version of the broadcast below. A PDF with this week's updates can be downloaded via the link below.2025-11-17 Current Federal Tax Developments

IRS provides relief to employers for reporting on qualified overtime and tips for 2025, more conservation easement cases, and more.

A taxpayer gets legal fees awarded due to the proper use of a qualifying offer, Congress has a bill to send to the President and more.

IRS outlines more information on the government shutdown and what activities are affected, more FAQs for OBBBA changes and more.

Bankruptcy trustee retrieves ERTC refund from management company that was employee's employer for tax purposes, IRS finds CDP case sent back to Appeals and more

IRS releases inflation adjusted amounts for 2026 tax years, IRS shutdown moves to phase two and more.

IRS announces the beginning of the end for paper check refunds, a taxpayer loses on a hobby loss case and more.

FInal regulations on designated Roth account catch-up contributions for qualified plans, states issued warnings on phishing/smishing attacks and more.

Tax Court issues decision on handling W-2 wages for QBI purposes for cannabis business, "placed in service" definition clarified for pre-IRA electric vehicle credits, and more developments.

IRS releases preliminary list of occupations for qualified tips deduction, entertainer found to be a California resident and more.

IRS releases guidance on changes in research and experimental expenditures, Sixth Circuit agrees with Second and Third Circuits on equitable relief for late Tax Court petitions in deficiency cases and more.

Simplification of reporting on Form 8308 proposed,. OBBBA additional guidance, thoughts on LLMs and tax law and more.

Second Circuit issues three opinions of interest, IRS issues OBBBA guidance on beginning of construction for solar and wind projects and more.

IRS announces no changes to be made to W-2s, 1099s, payroll reports and withholding tables in 2025 for OBBBA changes and more.

IRS Commissioenr announces expected late start of tax season upcoming, CAMT relief provided in Notice and more.

Two conservation easement cases (and one with a extra strong warning), fouling up a portability election, dealing with uncashed retirement plan checks and more.