Social Media Ideas for Tax Law

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...

Tax Law Update: June 2026

The most notable tax law developments of the past month

Wealth Tax Watch- A Mid-Year Update

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

Wyden's PPLI/PPVA Deja Vu Proposal: A Tax-Shelter Narrative, a Far Broader Statutory Rule and the Continuing Importance...

On April 13, Senate Finance Committee Ranking Member Ron Wyden (D-Or.) introduced the Protecting Proper Life Insurance from Abuse Act (S. 4279).1 The bill is substantively identica...

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...

Budget law cements permanent capital gains exemption for employee ownership trusts

The new budget law rewrites tax rules advisors use for business sales and CPP

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...

UC Davis School of Law Summer Tax Institute

I actually have something about tax law to post! Summer Tax Institute, June 15 – 18, 2026, UC Davis School of Law The 36th annual Summer Tax Institute, with, among others, UC Davis...

IRS designates certain CRAT arrangements as listed transactions

The final regulations target arrangements that the IRS says improperly use charitable remainder annuity trusts and annuities to eliminate ordinary income and capital gain on the sa...

Final regs. modify reporting obligations for Form 8308, Part IV

The final regulations published Tuesday by the IRS stick with the proposed regulations that modify information-reporting obligations for Part IV of Form 8308, Report of a Sale or E...

New York Appellate Court Upholds Workaround to Federal Preemption on State Sales Tax

States have the right to tax corporations doing business within their jurisdictions, but, pursuant to a federal law enacted in 1959, are prohibited from taxing net income of a corp...

The Eradication of the Five Percent Safe Harbor: Analyzing the Court’s Vacatur of IRS Notice 2025-42

Oregon Environmental Council v. Internal Revenue Service, No. 25-4400 (D.D.C. June 6, 2026) The landscape of clean energy tax planning underwent a seismic shift following th...

IRS rules label CRATs listed transactions

Final regulations identify charitable remainder annuity trusts as "listed transactions," akin to tax shelters that need to be disclosed to avoid penalties.

IRS Roundup: May 18 – May 26, 2026

The Section 530A Transfer Tax Safe Harbor: Analyzing Revenue Procedure 2026-25

Rev. Proc. 2026-25 (June 29, 2026), 26 CFR 601.601; IRC §§ 530A, 2010, 2503, 2505, 2642, 2662, 6019 Under Revenue Procedure 2026-25, the Internal Revenue Service (IRS) has e...

Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal

Volume 26, Number 49 (June 2026) of the eJournal of Tax Law and Policy, published by The Social Science Research Network (SSRN), and edited by Paul L. Caron: Jinyan Li (York Univer...

The Soroban Capital Partners SECA Tax Controversy: Partnership Items, Functional Analysis, and Appellate Oral Arguments

Soroban Capital Partners LP v. Commissioner, 161 T.C. 310 (2023); Soroban Capital Partners LP v. Commissioner, T.C. Memo. 2025-52; Soroban Capital Partners LP v. Commissioner,...

Federal Court Vacates IRS Notice 2025-42- Five Percent Safe Harbor May be Restored for Wind and Solar Projects

Bad-Facts FLP Causes Estate Tax Inclusion Under IRC Section 2036

An accuracy-related penalty was imposed on the tax deficiency.

Treasury Regulation Section 1.951A-2(c)(5) Held Invalid: Court of Federal Claims Rules Against Amortization Denials in P...

Keysight Technologies, Inc. & Subsidiaries v. United States, No. 25-137 (Fed. Cl. July 2, 2026) The United States Court of Federal Claims has held that the Department of...

Presumptive Taxation vs. Stamp Duty Valuation: ITAT Draws the Line Against Double Taxation

Presumptive Taxation vs. Stamp Duty Valuation: ITAT Draws the Line Against Double Taxation     The Income Tax Act contains several deeming provisions. Individually, they serve a sp...

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...

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...