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

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

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

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

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

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

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

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

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

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