Social Media Ideas for Tax Provision

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...

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...

The Application of New Section 68 to Trusts and Estates: Analyzing JCT Footnote 102 and Unresolved Ambiguities

IRC §68 as amended by the One Big Beautiful Bill Act, July 4, 2025 The One Big Beautiful Bill Act (OBBBA) fundamentally reshaped Section 68 by replacing the suspended Pease limitat...

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...

HMRC Guidance Provides Welcome Comfort for Private Equity Management Rollovers

Treasury Previews Regulatory Framework for New Section 25F Education Freedom Tax Credit

“Treasury Previews Education Freedom Tax Credit Guidance,” US Department of Treasury Release, June 10, 2026 In a significant move toward implementing the educational provision...

Transitioning to Automatic Exemption from Penalty: Procedural and Substantive Implications for Tax Practitioners

Internal Revenue Service, IR-2026-83, July 8, 2026 The Internal Revenue Service is implementing a significant procedural evolution regarding administrative penalty relief. The...

Net Operating Loss Carryforward and Carryback Provisions in Europe, 2026

Carryover provisions help businesses “smooth” their risk and income, making the tax code more neutral across investments and over time.

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...

Convert tax departments into profit centers

For many taxpayers — especially those with variable, limited or short-term tax capacity — credit transferability provides a practical and effective solution.

HMRC Consults on Aligning the Taxation of Distributions from Non-UK Resident Companies

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...

When Personal Security Is a Perk: SEC Reporting and Income Tax Implications for Corporate Security Benefits

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...

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,...

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...

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...

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...

Your best tax people are mostly moving data

  It’s 9 PM during provision close. Your most credentialed tax professional — fifteen years of experience, advanced credentials, top-quartile … The post Your best tax people are mo...

Navigating the Business Tax Account: Summer 2026 Enhancements, Access Protocols, and Strategic Implications for Practiti...

Internal Revenue Service. Summer 2026 Expanded Features for BTA. Fact Sheet FS-2026-11. July 2026. Retrieved from IRS.gov Newsroom. Internal Revenue Service. Business Tax Acco...

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...

Regulatory Shifts in Section 4960: Analyzing the Expanded Definition of Covered Employees under Notice 2026-36

IRS Notice 2026-36, Notice of Intent to Issue Regulations Under Section 4960, June 5, 2026 The Internal Revenue Service (IRS) and the Department of the Treasury have recentl...

Wealth Tax Watch- A Mid-Year Update

Final Regulations Modify Information Reporting for Section 751(a) Partnership Interest Exchanges

TD 10048, May 20, 2026 Under section 741 of the Internal Revenue Code (Code), "gain or loss recognized by a transferor partner upon sale or exchange of a partnership interes...