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Federal Scholarship Tax Credit Regulations: Comprehensive Technical Analysis of Temporary TD 10057 and Proposed REG-1171...

Federal Scholarship Tax Credit, Temporary Regulations, TD 10057, RIN 1545-BS17, 91 Fed. Reg. [page] (published Oct. 2, 2026) (codified at 26 C.F.R. pt. 1). Federal Scholarsh...

Immigration Status Restrictions on Refundable Individual Tax Credits: Analyzing the Preamble and Provisions of REG-11988...

Notice of Proposed Rulemaking, REG-119882-25, RIN 1545-BS06, ‘Application of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 to the Refunded Portion...

Allocation and Apportionment of Foreign Source Deductions: Technical Analysis of Proposed Regulations Under Sections 250...

Department of the Treasury, Internal Revenue Service, Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income, N...

Treasury’s Excluded Property Sales Income Regulations under Section 250: Deconstructing the Proposed Guidance for Tax Pr...

Application of Section 250(b)(3)(A)(i)(VII) to Sales or Other Dispositions of Property, REG-117130-25, 91 Fed. Reg. _____ (proposed Aug. 20, 2026) (to be codified at 26 C.F.R....

Technical Analysis of IRS Notice 2026-60: Updated Per Diem Substantiation Framework and Special Rates

Notice 2026-60, 2026-41 I.R.B. 1, Sept. 23, 2026 On an annual basis, the Internal Revenue Service releases administrative guidance updating the special per diem rates and list...

Employer Contributions to Trump Accounts and Nondiscrimination Rules under REG-101355-26: A Technical Analysis for Tax P...

Employer Contributions to Trump Accounts and Nondiscrimination Rules for Dependent Care Assistance Programs, REG-101355-26, 91 FR 16314 (proposed Aug. 11, 2026) The Departme...

Technical Analysis of Proposed Regulations Under IRC Section 1062: Installment Payment of Tax on Qualified Farmland Sale...

Notice of Proposed Rulemaking, Election to Pay in Installments Tax on Gain from Certain Farmland Property, REG-117095-25, 91 Fed. Reg. 63812 (proposed Sept. 29, 2026) The De...

Treasury Proposes Substantive Section 987 Relief for Controlled Foreign Corporations: Analysis of the CFC Exemption Elec...

Foreign Currency Gain or Loss of Controlled Foreign Corporations, REG-103844-26, 91 Fed. Reg. (proposed Aug. 14, 2026) On August 13, 2026, the Department of the Treasury and t...

Administrative Simplification of Accounting Method Changes for Research Expenditures and Residential Construction Contra...

Rev. Proc. 2026-32, September 4, 2026 The Department of the Treasury and the Internal Revenue Service (IRS) issued Revenue Procedure 2026-32 to provide updated administrative...

Technical Analysis of Treasury Decision 10056 and Proposed Regulations CC-00226466-26: The New Regulatory Framework for...

Trump Accounts, 91 Fed. Reg. 63200 (Sept. 30, 2026) (TD 10056); Trump Accounts, 91 Fed. Reg. 63215 (proposed Sept. 30, 2026) (CC-00226466-26) The Department of the Treasury an...

The Full Payment Requirement and the Presumption of Correctness: Jurisdictional Lessons from Pellegrino v. United States

Pellegrino v. United States, No. 1:26-cv-00403, 2026 WL (Fed. Cl. Aug. 20, 2026) In Pellegrino v. United States, No. 1:26-cv-00403 (Fed. Cl. Aug. 20, 2026), Judge Philip S....

Treasury Finalizes Updated User Fee for Estate Tax Closing Letters: A Technical Analysis for Tax Practitioners

Treasury Decision 10055, RIN 1545-BS10, Sept. 25, 2026 The Department of the Treasury and the Internal Revenue Service (IRS) have issued Final Regulations (Treasury Decision 1...

CFTC Final Rule Establishes 30% Presumption for Some Whistleblower Awards

On Sept. 16, 2026, the Commodity Futures Trading Commission published a final rule revising its whistleblower regulations. The final rule will create a presumption that a whistlebl...

Implementing Trump Account Eligible Investments: An Analytical Analysis of the Proposed Regulations

Guidance on Eligible Investments for Trump Accounts, CC-00349938-26, RIN 1545-BS14, 26 CFR Part 1, FR Doc. 2026-17123 (Filed Aug. 20, 2026, 8:45 a.m., published Aug. 21, 2026)....

Columbia Floating Rate Fund Q2 2026 Commentary

Tax Practice Alert: Alteration of the Perjury Jurat Invalidates Refund Claims Under IRC Section 7422

Darrin Johnson, Jr. v. Internal Revenue Service, No. 1:25-cv-02117 (D. Md. Sept. 11, 2026) For tax professionals advising clients on tax controversy and refund claims, maint...

Analyzing the New Regulations on the Car Loan Interest Deduction: A Technical Guide for Tax Professionals

Car Loan Interest Deduction, T.D. 10054, 91 Fed. Reg. 18219 (scheduled for publication Sep. 8, 2026) The release of the final regulations under Treasury Decision (T.D.) 10054...

Trust Fund Recovery Penalty Willfulness and the Capping Effect of Corporate Offers-in-Compromise: A Technical Analysis o...

Amodio v. Commissioner, T.C. Memo. 2026-96, Docket No. 9959-22L (Sept. 28, 2026) For tax controversy practitioners, Certified Public Accountants, and Enrolled Agents, naviga...

San Francisco Amends its Fair Chance Ordinance

On July 10, 2026, the San Francisco Board of Supervisors amended the Fair Chance Ordinance (FCO), placing additional restrictions and requirements on employers who make employment...

Proposed Section 1.501(c)(3)-2: Re-Evaluating Racial Nondiscrimination Requirements for Private School Tax Exemptions

Department of the Treasury, Internal Revenue Service, Notice of Proposed Rulemaking: Racial Nondiscrimination in Private Schools, REG-119986-25, RIN 1545-BS05, FR Doc. 2026-181...