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Supreme Court Rules Tax Court Lacks Jurisdiction Where IRS Withdraws Levy (Commissioner v. Zuch, SCt.)
The U.S. Tax Court lacks jurisdiction over a taxpayer’s appeal of a levy in a collection due process hearing when the IRS abandoned its levy because it applied the taxpayer’s later year overpaymen...

IRS Collects More Than $5 Trillion In 2024 (IR 2025-63)
The Internal Revenue Service collected more than $5.1 trillion in gross receipts in fiscal year 2024. It is the first time the agency broke the $5 trillion mark, according to the 2024 Data Book, an a...

Change of Accounting Method Procedures Updated (Rev. Proc. 2025-23)
The IRS has released guidance listing the specific changes in accounting method to which the automatic change procedures set forth in Rev. Proc. 2015-13, I.R.B. 2015- 5, 419, apply. The latest guidan...

Additional Transition Relief Provided for Brokers Required to File Form 1099-DA (Notice-2025-33; IR-2025-67)
The Treasury Department and IRS have issued Notice 2025-33, extending and modifying transition relief for brokers required to report digital asset transactions using Form 1099-DA, Digital Asset Proc...

Tax Court Lacked Jurisdiction as IRS Failed to Establish Valid Notice of Deficiency (Cano, TCM)
The IRS failed to establish that it issued a valid notice of deficiency to an individual under Code Sec. 6212(b). Thus, the Tax Court dismissed the case due to lack of jurisdiction....

TEFRA Partnership not Entitled to Exclude Partners’ Distributive Shares from Self-Employment Income (Soroban Capital Partners LP, TCM)
A limited partnership classified as a TEFRA partnership was not entitled to exclude its limited partners’ distributive shares from net earnings from self-employment under Code Sec. 1402(a)(13). The...

Trump Signs First Two Phases of Coronavirus Economic Response Package; Phase Three Underway
President Trump signed into law the first two phases of the House’s coronavirus economic response package. Meanwhile, the Senate has been developing and negotiating "much bolder" phase three legis...

Trump Administration Extends 2020 Tax Filing Season Through July 15
"At President Trump’s direction, we are moving Tax Day from April 15 to July 15," Treasury Secretary Steven Mnuchin said in a March 20 tweet. "All taxpayers and businesses will have this additiona...

Due Date for Federal Income Tax Payments Extended to July 15
The Treasury Department and IRS have extended the due date for the payment of federal income taxes otherwise due on April 15, 2020, until July 15, 2020, as a result of the ongoing coronavirus (COVID-1...

HSA High-Deductible Health Plans Can Cover Coronavirus Costs
The IRS has provided emergency relief for health savings accounts (HSAs) and COVID-19 health plans costs. Under this relief, health plans that otherwise qualify as high-deductible health plans (HDHPs)...

AICPA Asks for More QBI Deduction Guidance
The American Institute of CPAs (AICPA) has requested additional guidance on tax reform’s Code Sec. 199A qualified business income (QBI) deduction....

Reporting Relief for U.S. Individuals’ Transactions With Certain Foreign Trusts
The IRS has issued guidance that: exempts certain U.S. citizens and residents from Code Sec. 6048 information reporting requirements for their transactions with, and ownership of, certain tax-favor...

2021 Budget Outlines Administration Priorities for Extending Tax Cuts, Increased IRS Funding
On February 11, the White House released President Donald Trump’s fiscal year (FY) 2021 budget proposal, which outlines his administration’s priorities for extending certain tax cuts and increasin...

House Democrats Unveil Framework for $760 Billion Infrastructure Plan
House Committee on Transportation & Infrastructure, "Moving Forward Framework"; House Ways and Means Committee, January 29 hearing witnesses’ testimony...

House Writers Debate Effects of Corporate Income Tax Cut
House Democratic and Republican tax writers debated the effects of tax reform’s corporate income tax cut during a February 11 hearing convened by Democrats. Democratic lawmakers have consistently ca...

Calculation of “Average Income” Minimum Set Aside Test for Low Income Housing Credit Explained
Taxpayers claiming the low-income housing credit should apply the "average income" minimum set aside test by reference to the "very low-income" limits calculated by the U.S. Department of Housing ...

Guidance Provided on Qualifying for EITC
The IRS has provided guidance on qualifying for the Earned Income Tax Credit (EITC). The EITC is a refundable tax credit that is intended to be a financial boost for families with low to moderate inco...

Proposed Regulations Reflect Changes to Wage Withholding, Redesigned W-4
The IRS has proposed regulations with guidance for employers on withholding federal income tax from employee’s wages....

Trump Signs Bipartisan Year-End Government Spending, Tax Package
On December 20, President Donald Trump signed the bipartisan, year-end government spending and tax package, just hours before federal funding was set to expire. Trump's signature on the over 2,000-pag...

Individual Mandate Ruled Unconstitutional
The Fifth Circuit U.S. Court of Appeals ruled that the Patient Protection and Affordable Care Act’s (ACA) ( P.L. 111-148) individual mandate is unconstitutional because it can no longer be read as ...

Qualified Opportunity Zone Investment Regulations Finalized
Proposed qualified opportunity zone regulations issued on October 29, 2018 ( REG-115420-18) and May 1, 2019 ( REG-120186-18) under Code Sec. 1400Z-2 have been finalized with modifications. The reg...

Final Regulations on Property Transfers by U.S. Persons to Partnerships with Related Foreign Partners
The IRS has issued final regulations that provide guidance on transfers of appreciated property by U.S. persons to partnerships with foreign partners related to the transferor. Specifically, the regul...

Final Regulations Address Withholding on U.S. Source Income
The Treasury and IRS have issued final regulations on the due diligence and reporting rules for persons making certain U.S. source payments to foreign persons. Guidance is also provided on reporting b...

New Rules Proposed on Charitable Contribution Related to SALT Benefits
The IRS has released new proposed rules related to charitable contributions made to get around the $10,000/$5,000 cap on state and local tax (SALT) deductions. The proposed regulations:...

Final and Proposed Regulations Address Foreign Tax Credit
The IRS has issued highly anticipated final regulations on the significant changes made to the foreign tax credit rules by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97). The final regulations retain...

Partner Tax Basis Capital Reporting Not Required Until 2020 Partnership Tax Years
The IRS has released guidance that provides that the requirement to report partners’ shares of partnership capital on the tax basis method will not be effective for 2019 partnership tax years, but w...

Final Regulations on Calculation of UBTI Issued
The IRS has released final regulations that present guidance on how certain organizations that provide employee benefits must calculate unrelated business taxable income (UBTI) under Code Sec. 512(a)....

Final Rules Adopted on Changes to Estate Tax Exclusion Amount
The IRS has issued Reg. §20.2010-1(c) to address the effect of the temporary increase in the basic exclusion amount (BEA) used in computing estate and gift taxes. In addition, Reg. §20.2010-1(e)(3) ...

Cryptocurrency Guidance, Virtual Currency FAQs Released
The IRS has released cryptocurrency guidance and frequently asked questions (FAQs) on virtual currency....

Proposed Regulations Provide Guidance on Section 382(h) Built-in Gain and Loss Computation
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