The Third Circuit affirmed the Tax Court’s broad interpretation of “intent” under Sec. 6501(c)(1).
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TOPICS
Tax
Second Circuit denies SALT cap workaround
Final regulations prohibiting a federal charitable deduction for contributions to a state or local fund for which the donor receives a state or local tax credit are upheld under a Loper Bright analysis.
FBAR penalty case dismissed on constitutional grounds
A district court held that the government violated a taxpayer’s Seventh Amendment right to a civil jury trial in an FBAR case.
Line items
Annual inflation adjustments announced for tax year 2026 … Social Security Administration head to also serve in new IRS role … Job cuts mean strong 2025 tax season may be hard to repeat, IRS watchdog warns … IRS removes associated property rule in final interest capitalization regulations … IRS withdraws prop. regs. affecting corporate spinoff transactions
Filing season quick guide — tax year 2025
This annual tax quick guide highlights dollar thresholds, tax tables, standard amounts, credits, and deductions.
Get ready for tax season
Guide clients through the significant changes in H.R. 1.
IRS updates FAQs on business interest limitation, premium tax credit
The updates reflect changes made in H.R. 1, P.L. 119–21, commonly known as the One Big Beautiful Bill Act.
Corporate Transparency Act, source of BOI reporting mandate, held constitutional
Despite the Eleventh Circuit holding that the Corporate Transparency Act is constitutional, an interim rule from Treasury means that domestic companies are not subject to beneficial ownership information reporting requirements.
Even an expert says: Digital asset reporting creates headaches
At the AICPA National Tax Conference, digital assets expert Nik Fahrer, CPA, sympathized with tax pros who dread the upcoming tax season because of digital asset reporting requirements.
Why 2026 is another ‘big tax year’
Get an inside look at the AICPA’s tax advocacy focus, including improving taxpayer service and shaping IRS processes for a smoother filing season. Listen to the podcast episode or read the Q&A with the AICPA’s vice president–Tax Policy & Advocacy.
IRS clarifies health savings account changes in H.R. 1 in new notice
Among other changes, the guidance explains that bronze and catastrophic plans are considered HSA-compatible under Sec. 223.
PTEs need more notice of changes, more time to respond, AICPA says
In a letter to Treasury and the IRS, the AICPA seeks changes to tax reporting requirements for partnerships and S corporations.
IRS announces prop. regs. on international tax law provisions in OBBBA
The proposed regulations will deal with changes included in H.R. 1, P.L. 119-21, commonly known as the One Big Beautiful Bill Act.
Where CPAs stand on economic sentiment, what’s next for the JofA podcast
This episode summarizes results of a recent quarterly survey on economic and business sentiment, mentions IRS news, and previews future content. Listen to the episode or read the transcript.
IRS outlines details for Trump accounts
The IRS released initial details on Trump accounts, a new type of IRA for some children. Also, a billionaire business executive pledged $6.25 billion to provide 25 million children with a $250 contribution to a Trump account.
New regs. reshape 1% stock buyback tax, drop funding rule
The IRS published final regulations that scrap the proposed funding rule and ease compliance for M&A deals, preferred stock, and netting provisions.
Managing MNE subsidiaries during tariff shocks
Multinational enterprises’ subsidiaries need other incentives to optimize their performance if transfer pricing policies guarantee them a routine profit.
Second Circuit reverses Tax Court’s dismissal of deficiency petition
The appellate court holds that the Sec. 6213(a) deadline for filing a Tax Court deficiency petition is nonjurisdictional and subject to equitable tolling.
Tax Court denies bad-debt deduction
Advances made by a taxpayer in its business of managing an arena were not bona fide debt, and the taxpayer was not entitled to a bad-debt deduction when the advances became worthless.
Estate’s portability election held invalid
The taxpayer’s predeceased spouse’s estate failed to timely file an estate return and did not qualify for the safe harbor in Rev. Proc. 2017-34, so its portability election was invalid, the Tax Court held.
Features
FROM THIS MONTH'S ISSUE
Drafting an AI policy that actually works
As AI use accelerates, many firms are discovering their policies haven’t kept pace. This article breaks down what CPAs and finance leaders should consider when drafting an AI policy that’s practical, flexible, and fit for real world use.
