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by The Ohio Society of CPAs
Federal Tax Update Podcast Series
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This week we look at: Valuation of Remainder Interest Gifts Upon Trust Termination: State Law and Net Gift Adjustments in Lewis v. Commissioner Revenue Procedure 2026-26: Technical Overview of 2027 Indexing Adjustments for Premium Tax Credits and Affordability Standards Limitations of Interest Abatement Claims Under I.R.C. § 6404(e)(1) in the Context of ERC-Driven Amendments Section 6015(c) Relief and the Substantiation Trap: An Analysis of Anderson v. Commissioner Navigating the AICPA's New Tax Services Independence Standards: A Guide for Practitioners
This week we look at: Partnership Recourse Rules: Conditional DROs will not establish EROL under § 1.752-2. Mileage Rate Adjustment: Business standard mileage rate rises to 76 cents on July 1, 2026. Business Tax Account: Modernized self-service portal expands features but requires active annual maintenance. Litigation Legal Fees: FCRA settlements are taxable gross income without above-the-line deduction. Corporate Reorganizations: Tax Court invalidates regulation limiting 100% DRD in post-Loper Bright era. ERC Litigation Realities: Exhaustion loophole rejected; notice pleading standards approved in refund suits. Conservation Easements: Valuation must be grounded in immediate local market demand, not speculation.
This week we look at: Transitioning from First Time Abate (FTA) to Automatic Exemption from Penalty (AEP) Strict Enforcement of Tax Refund Statutes of Limitations Employee Retention Credit (ERC) Refund Claims & Pleading Standards Pandemic-Era Persistence of New York's Convenience of the Employer Rule Invalidity of Treasury Regulation Section 1.951A-2(c)(5) Non-Shareholder Capital Contributions vs. Compensation Final Section 1035 Exchange & Corporate Reorganization Regulations Reclassification of Abusive CRAT Structures as Listed Transactions The National Taxpayer Advocate's Perspective on AEP
This week we look at: Section 7508A(d) and Interest on Pre-COVID-19 Disaster Tax Deficiencies The Soroban Capital Partners SECA Tax Controversy Pleading Requirements for the Employee Retention Credit (Tapestry Senior Housing) ERC Causation and the Essential Business Hurdle (RAAM Construction) The Section 530A Transfer Tax Safe Harbor (Rev. Proc. 2026-25) Penalty Supervisory Approval Verification in CDP (Besicorp Group) Retroactive ERC Deadlines & Constitutional Challenges
This week we look at: Nominal S Corporation Ownership and the Abuse Exception Recapping the ERC via Section 7405 Civil Actions Constructive Dividends, Formalities, and Civil Fraud CDP Hearings, Offer-In-Compromise, and RCP Calculations Professional Responsibility and Responsible AI Use Rigorous Proof for ERC "Partial Suspension" Claims
This week we look at: Relief from Ineffective S Corporation and QSub Elections Procedural and Jurisdictional Limits in Challenging IRS Guidance Medicaid Gross Receipts, Cohan Estimations, and Professional Reliance Standards and Deceit in Supervised Release Transitional Guidance on Qualified Opportunity Zones
This week we look at: Application of New Section 68 to Trusts and Estates Assessing the Risks of Hindsight in Late § 475(f)(1) Elections The Eradication of the 5% Safe Harbor (Clean Energy) Limits of § 2036(a) and Tax-Motivated Transfers Section 183 Hobby Losses & Penalties New Section 25F Education Freedom Tax Credit
This week we look at: Proposed Increase to Estate Tax Closing Letter User Fee Divergent Causation Standards for ERC Eligibility Valuation Extremes in Conservation Easements Substantiating Mortgage Interest Deductions Taxation of Cryptocurrency Staking Rewards Section 4960 and "Covered Employees" FBAR Compliance and IRS Agent Authority
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