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

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

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

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

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

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

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

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

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

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

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