Social Media Ideas for Revenue Memorandum Circular

Economic Risk of Loss and Conditional Deficit Restoration Obligations

Chief Counsel Advice Memorandum Number: 202628009, Office of Chief Counsel, Internal Revenue Service (Written: May 29, 2026, Redacted Version Released: July 10, 2026) The ma...

ERC Refund Claims and the Pleading Standard for Government Orders: Analysis of Region IV Mental Health Services v. Unite...

Region IV Mental Health Services v. United States, No. 3:26-CV-12-RPC-JMV, 2026 WL ___ (N.D. Miss. July 1, 2026) The controversy in Region IV Mental Health Services v. United...

Technical Analysis of TD 10051: The Reclassification of Abusive CRAT Structures as Listed Transactions

TD 10051, July 9, 2026 The issuance of TD 10051, which finalizes the proposed rules set forth in REG-108761-22, represents a definitive strategic shift in the Internal Reven...

Technical Review of Announcement 2026-11 Regarding Revised Standard Mileage Rates

Announcement 2026-11, 2026-4 I.R.B. 378, July 10, 2026 The Internal Revenue Service has issued Announcement 2026-11, which serves as a formal modification to the previously is...

Procedural and Jurisdictional Limitations in Challenging IRS Notice 2021-20: An Analysis of First Source Employee Manage...

First Source Employee Management, Inc. v. United States of America, Case No. 1:24-cv-02209-CEF, 2026 WL 3589421 (N.D. Ohio June 11, 2026). The litigation originated from the P...

Section 7405 Erroneous Refund Suits and the Employee Retention Credit: The Impact of Plastic Film, LLC v. United States

Plastic Film, LLC v. United States, Civil No. 5:25-cv-30-DCB-LGI (S.D. Miss. June 22, 2026) The Employee Retention Credit (ERC) has been one of the most heavily scrutinized...

Latest Tax Updates: Section 7508A Refund Claims, Whistleblower Award Eligibility, and Court Restrictions on IRS Collecti...

Regulation: MAA regulatory instructions (RI)

RIs will be issued by the MAA to provide direction, and have the same authority as MAA regulation

Medicaid Gross Receipts, Cohan Estimations, and the Limits of Professional Reliance: A Technical Analysis of Branch v. C...

Branch v. Commissioner, T.C. Memo. 2026-51, Docket No. 7214-20 (Filed June 17, 2026) In Branch v. Commissioner, T.C. Memo. 2026-51, the United States Tax Court addressed sev...

Back in Business? The IRS Revives “Significant Issue” Rulings for Corporate Transactions

On May 5, 2026, the Internal Revenue Service (“IRS”) released Revenue Procedure 2026-21 (the “Rev. Proc.”), which reinstates a program under which taxpayers may request private let...

KRA Sends Notice to Some Manufacturers After Removal of Excise Tax

The notice follows amendments introduced under the Finance Act, 2026, which eliminated and introduced some levies for select manufacturers.

IRS Adds Two Substances to List of Chemical Substances Subject to Superfund Excise Tax

The Internal Revenue Service (IRS) published a notice of determinations on June 26, 2026, that the list of taxable substances is modified to include the following two substances: c...

Tax Professional Alert: IRS Proposes Increase to Estate Tax Closing Letter User Fee

REG-103193-26, June 1, 2026 The Internal Revenue Service (IRS) has issued a notice of proposed rulemaking (REG-103193-26) that will directly impact tax practitioners and exe...

BIR renews multi-sectoral consultative mechanism, expands BIR-PMSG

  MANILA, Philippines — The Bureau of Internal Revenue (BIR) renewed its multi-sectoral consultative mechanism with business groups, professional organizations, foreign chambers, a...

Capital Contributions vs. Compensation: Analyzing Ownership and Taxability in Manufacturing Expansion Agreements

Thermal Circuits, Inc. v. Commissioner, T.C. Memo. 2026-29 (July 7, 2026) In the complex intersection of supply chain financing and tax characterization, the distinction betwe...

IRS roundup: May 29 – June 8, 2026

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 29, 2026 – June 8, 2026. May 29, 2026: The US Department of the Treasu...

Analysis of Collection Due Process and Reasonable Collection Potential in Tooke v. Commissioner

Tooke v. Commissioner, T.C. Memo. 2026-54, June 23, 2026 The United States Tax Court recently issued a memorandum opinion in Tooke v. Commissioner, T.C. Memo. 2026-54, providi...

Taxation of Cryptocurrency Staking Rewards under Section 61

Alvie N. Paschall and Patricia C. Paschall v. Commissioner of Internal Revenue, T.C. Memo. 2026-46 (June 4, 2026) The litigation in Paschall v. Commissioner involves the tax t...

Retroactive Employee Retention Credit Deadlines and the Fifth Amendment: An Analysis of Key Meetings, Inc. v. United Sta...

Key Meetings, Inc. v. United States, Case No. 25-cv-06520-WHO (N.D. Cal. June 26, 2026) and Juggler Dave & Friends, LLC v. United States, 181 Fed. Cl. 52 (2026) The retr...

NRS launches Rev360 to ease tax compliance

The central tax agency launched the platform on Wednesday, reaffirming its commitment to boost voluntary tax compliance and provide seamless access to tax services. The post NRS la...

IRS Roundup: May 18 – May 26, 2026

Regulation: Withdrawn MAA regulatory instructions (RI)

RIs will be issued by the MAA to provide direction, and have the same authority as MAA regulation.

IRS roundup: June 10 – June 21, 2026

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for June 10, 2026 – June 21, 2026. June 9, 2026: A Treasury Inspector General...

IRS Notice 2026-40: Comprehensive Analysis of Post-OBBBA Transitional Guidance on Qualified Opportunity Zones

Notice 2026-40, Internal Revenue Service (June 2026). For practitioners advising clients on Qualified Opportunity Zone (QOZ) investments under the Internal Revenue Code (the C...