Limitations on transactions between related parties include restrictions on installment sales of property and potential reallocation of tax benefits of certain personal services corporations.
IRS Practice & Procedure
Company’s $1.6 billion ‘break fee’ payment treated as ordinary deduction
A proposed merger agreement’s rights and obligations were in the nature of services, so a fee paid to terminate was not treated as a capital loss, the Tax Court held.
Supreme Court: Tax Court lacks jurisdiction when levy is satisfied
Because the IRS had offset a taxpayer’s liability from subsequent refunds, it was no longer pursuing a levy, and a petition was properly dismissed under Sec. 6330, the high court held.
Like-kind exchanges of real estate: Building on the basics
Sec. 1031 like-kind exchanges enable tax deferral in complex real estate deals, including multi-property, reverse, and straddle exchanges.
IRS withdraws prop. regs. affecting corporate spinoff transactions
The proposed regulations were withdrawn in response to comments that criticized the proposed guidance, according to the IRS.
IRS shutdown plan: Employees stay on the job for first 5 workdays
The IRS would use money from the Inflation Reduction Act to keep the agency’s over 74,000 employees working for the first five days of a potential government shutdown.
IRS trims PTIN fee as renewal season nears
The fee reduction comes as a result of a biennial review of PTIN fees.
Paper tax refund checks on the way out as IRS shifts to electronic payments
The IRS will phase out the use of paper checks for refunds beginning Sept. 30 and will publish detailed guidance later.
IRS keeps per diem rates unchanged for business travel year starting Oct. 1
In its list of high-cost and low-cost localities, the IRS kept per diem rates for travel, meals, and incidental expenses unchanged for the new annual period starting Oct. 1.
AICPA urges IRS to modernize estate and trust tax forms
In a letter to the IRS, the AICPA said the changes align with an executive order mandating that all federal tax payments and refunds be processed electronically.
Preserving the limitation statute for ERC claims
The IRS often denies employee retention credit claims by a Letter 105-C notice of disallowance, which can risk taxpayers’ losing a refund due to the statute of limitation.
IRS finalizes regulations for Roth catch-up contributions under SECURE 2.0
The final regulations are similar to the proposed regulations issued in January, with some changes that the IRS said were made in response to comments.
IRS warns taxpayers: Social media advice can lead to costly penalties
Misleading posts about credits like the fuel tax credit are landing taxpayers in trouble — with fines up to $5,000 for frivolous returns.
Treasury posts preliminary list of jobs eligible for no tax on tips
The list has a variety of occupations that customarily receive tips, including bartenders, dancers, and digital creators.
Tax Court addresses dueling motions to dismiss
The court granted the IRS’s motion because the petition was untimely and denied the taxpayer’s contending that the Service’s deficiency notices were invalid.
Scope of review in passport cases is de novo
The Tax Court held that its review of a certification of a seriously delinquent tax debt potentially denying or revoking a taxpayer’s passport could include evidence introduced at trial.
Practical considerations for taxpayers and advisers following Loper Bright and Corner Post
Taxpayers and advisers should reckon with the two Supreme Court decisions when evaluating tax return positions that may conflict with existing administrative guidance.
Results of recent academic research may aid practitioner planning
Five tax research articles published in the past year in academic journals provide potentially valuable insights for practitioners.
Draft 2026 Form W-2 includes boxes and codes for tips and overtime
The IRS said previously that it will not release a new form for 2025, even though the temporary H.R. 1 provisions are effective this year, but it will provide transition relief.
IRS seeks to fill ‘critical vacancies’ as workforce declines 25%
The IRS has asked some employees who accepted deferred resignation offers if they want to stay on the job.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
