Current Federal Tax Developments

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 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,...

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.