This week we look at:

• Reasonable Cause Relief Under the Small-Corporation Provision for Form 5472 Penalties
• Extending the Statute of Limitations for Disallowed ERC Claims
• Legislative Update: House Passes Comprehensive Tax Administration and Relief Bills
• Anticipated IRS Guidance Following the Rescheduling of Medical Marijuana
• Analysis of the New Dyed Fuel Excise Tax Refund Regulations Under Section 6435
• Executive Order on Retirement Savings and Its Interaction with IRC Section 6433

This week we look at:

• Tax Implications of the Rescheduling of State-Licensed Medical Marijuana
• Disallowance of COVID-19 Leave Credits: A Review of Substantiation and Trade or Business Requirements
• The Tenth Circuit Codifies the Reach of the Economic Substance Doctrine Over Mechanical Statutory Compliance
• Substantiation, Entity Indebtedness, and Business Expense Deductibility: An Analysis of the Simmons Case
• Treatment of Loyalty Rewards Program Funds and the Claim of Right Doctrine
• Valuation and Penalty Controversies in Estate Tax Examinations

This week we look at:

• A Technical Analysis of the Final Section 224 Regulations on the Qualified Tip Deduction

• Analysis of Proposed Regulations on Information Reporting Thresholds and Wagering Losses (REG-113229-25)

• U.S. District Court Splits Its Ruling on Micro-Captive Disclosure Mandates

• IRS Reduces Enrolled Agent Special Enrollment Examination User Fees: An Analysis of the Interim Final and Proposed Regulations

• Taxation of Terminated Life Insurance Policies: An Analysis of Constructive Receipt and Investment Interest

This week we look at:

• Corporate Capacity and State Law Revivor

• Digital Asset Identification Relief

• Interest and Bonus Depreciation Relief

• ERC Disallowances and Legal Standing

• Substantiation Rules for Emergency Vehicles

• Partnership Audits and Due Process

• Social Security Repayments

This week we look at:

• Proposed Regulations for IRC Section 530A "Trump Accounts"
• IRC Section 6434 Trump Account Pilot Program
• Micro-Captive Scrutiny Formalized
• BBA Audits: Notice Defects and the Statute of Limitations

This week we look at:

• Fiduciary and Beneficiary Liability for Unpaid Estate Taxes
• Retroactive Entity Classification and Partnership Basis
• 2026 Passenger Auto Depreciation Limits
• Passport Certification & Victimization Defenses
• Passport Revocation in Collection Suits
• Waiver of Foreign Earned Income Exclusion Time Rules
• New Digital Asset Reporting Landscape (Form 1099-DA)

This week we look at:

• Required Minimum Distribution Regulations Delay
• CDP Proceedings and Underlying Liabilities
• Section 743(b) Adjustments and Economic Substance
• Assessability of Section 6038(b) Penalties

This week we look at:

• Supreme Court Invalidates Executive Tariffs Under IEEPA
• Special Depreciation Allowance Under the OBBBA
• CAMT Adjustments and Relief
• Circuit Split on Third-Party Fraud
• Valuation and Penalties in Syndicated Conservation Easements