Current Federal Tax Developments

Senate Finance Committee release draft of tax provisions, IRS manages to foul up addressing a notice of deficiency and more.

The Supreme Court sides with the IRS on a CDP Levy issue, an updated list of automatic accounting method change procedures is issued and more.

Ninth Circuit looks at the (lack of) a connection between a cancelled debt for a debtor and a bad deduction for a (related) debtor, Supreme Court decides a Constitutional SUTA/FUTA issue and more.

A second try at mounting a challenge to New York's convenience of the employer rule, a look at reasonable cause in the context of a late filing penalty and more.

Key provisions in proposed tax bill that impact passthroughs, a case looking at the claim of right doctrine, and more.

Another Circuit looks into the equitable tolling issue for Tax Court deficiency petitions, an US Air Force civilian contractor issued orders to move cannot claim moving expenses and more.

Congress considers modifying PL 86-272's solicitation provision, 2026 HSA inflation adjusted numbers released and more.

We discuss a CDP case argued before the US Supreme Court, a decision from the same court related to prohibited transactions under ERISA and more.

Taxpayer fails to justify equitable relief for late filing of employment tax related Tax Court petition, Tax Court found horse operation was subject to the hobby loss rules and more.

Congress blocks DeFi regulations, ERC consultant denied requested relief.

Taxpayers get into hot water by having too good to be true tax shelters, while another runs afoul of the duty of consistency.

This week we look at:Congress Passes Resolution to Nullify Final Regulations on DeFi Information Reporting in TD 10021Interim Final Rule Limiting BOI Filing Requirements Released by Treasury DepartmentSubstantiating Depreciation for Converted Property: A Look at Smith v. CommissionerExecutive Order Will Generally Bar the Use of Paper Checks to Make Payments to or Receive Refunds from Treasury, Including Tax Related OnesJones et al. v. Commissioner: A Deep Dive into the Tax Court's Scrutiny of a Microcaptive Insurance ArrangementNavigating Jurisdictional Hurdles in Tax Refund Claims: A Look at Hamilton v. United StatesNinth Circuit Affirms Willful Failure to Pay Trust Fund Taxes: A Case Study for CPAsAn 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

IRS provides "simplified method" for reporting income tax impacts of ERC claims, a taxpayers finds there can be issues with following IRS advice and more.

IRS releases memorandum on when a theft deduction is available for a scam victim, ERTC suits filed asking for a refund, and more.

Treasury announces major reduction in those required to file BOI reports, the state of California looks to collect taxes for services performed entirely in Connecticut and more.

FinCEN announces additional BOI relief and timeframe for additional guidance, IRS announces dirty dozen tax scams for 2025 and more.

Final bar to BOI enforcement removed by Texas court, March 21, 2025 filing deadline set, and more.

Taxpayers found not to be in a trade or business and not a victim of theft, another conservation easement loss for taxpayers, House Ways & Means Committee unanimously advances four bills and more.

The new Administration begins filing responses in CTA litigation, continuing to look to remove the bar to enforcement, a taxpayer discovers the downside of having poor and disorganized records and more.

Tax Court reduces donation amount to less than 1/3 of original amount claimed, taxpayer's decision to play hardball in a collection issue backfires. and more.

Supreme Court rules on BOI injunction, but no real change in status due to second injunction issued after the case went to the court along with other developments.

IRS releases two sets of proposed regulations under the SECURE 2.0 Act, IRS agrees to hear case on Tax Court jurisdiction in CDP cases and more.

IRS releases filing and payment relief for those affected by California wildfires, Update on Section 530 independent contractor provisions and more.

This week we discuss IRS relief for using specific identification of digital assets for sales, more BOI developments and IRS gives up on listed transaction issues.

BOI updates continue throughout the week, Ninth Circuit rules on all events test issue and Tax Court again imposes functional test on state law limited partners

IRS proposes revisions to Circular 230 and more developments in the BOI report deadlines, but for now we still have an injunction against enforcement of the law--but we are waiting on the Fifth Circuit's ruling before we can be relatively sure we don't have a January 1, 2025 deadline.

IRS expands Business Tax Accounts to more entities and to include more features, two new tax bills signed into law and the DOJ asks for a stay on the injunction related to the CTA pending its appeal.

US District Court issues temporary injunction barrijng enforcement of BOI reporting regime, FinCEN responds and Congress passes two not terribly major tax bills.

IRS releases form to optionally use to make a Section 83(b) election as well as extending two relief provsions

IRS to use IP-PINs to help in cases where taxpayers discover a dependent was claimed on another taxpayer's return and more.

Tax Court looks at how to handle a situation where a partner deducted losses in excess of basis in a year no longer open to assessment and more.

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.

The IRS releases inflation adjusted retirement plan numbers and an email on dealing with self-employment and net investment income taxes on BBA partnership exams

IRS releases inflation-adjusted numbers, and another US District Court denies a request for an injunction barring enforcement of the BOI reporting requirements.

IRS opens up PTIN registration, staking returns to a Tennessee District Court and more.

Issues confusing CPAs regarding the BOI, including if their own firm needs to file the report.

DOJ schedules hearing on proposal to reschedule marijuana and we review BOI issues that seem to cause confusion.

The IRS announces second ERC Voluntary Disclosure Program and the National Taxpayer Advocates comments on the recent IRS Notices of Disallowances on ERC claims.

A discussion of possible authorities for deductions for specific types of online frauds and the IRS makes announcement on the future of ERC credit processing.

Cloture vote fails on the Senate on House passed tax bill and District Court declines to issue preliminary injunction ordering the IRS to end the ERC credit processing moratorium.

The IRS issues more ERC guidance and FinCEN adds more guidance to their FAQ on BOI reporting.

IRS finalizes regulations on RMDs and clears up the starting point for RMDs for those born in 1958.

A big week for FinCEN BOI reporting developments and another S corporation loses its status due to a failure to file elections for trust shareholders

A review of end of term Supreme Court cases that may bring more Treasury Regulations under challenge in court.

National Taxpayer Advocate states IRS will automatically begin issuing FTA relief, but not until 2026, Ninth Circuit issues a ruling on the statute of limitations and more.

Supreme Court finds 965 transition tax is constitutional, IRS gives update on ERC claim processing and more.

Taxpayer Advocate warns about AI in consumer tax return preparation products, IRS provides last minute estimated tax relief to certain large corporations and more

The Supreme Court decides a key estate tax case for closely held corporate interests, a taxpayer denied IRA relief and more.

IRS announces continuation of Direct File program and issues for electing S corporation status as an LLC.

Another PLR for a missed QSST election, two court cases on misleading silence of a party and more.

IRS discusses ERC exam, tax adviser sues IRS to force the agency to restart ERC claims processing, and more