FICPA Podcasts

Federal Tax Update: Revisiting Previously Discussed Cases

https://vimeo.com/1089225829?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/6/2/2025-06-02-revisiting-previously-discussed-cases

This week we look at:

• Self-Employment Tax for Limited Partners (Soroban II)
• Presidential Tariffs Under IEEPA (USCIT Decision & Federal Circuit Stay)
• Massachusetts Source Income (Welch Case Petition)
• Foreign Gift Penalties (Huang Case)

 

Federal Tax Update: Second Challenge to Convenience of the Employer Rule

https://vimeo.com/1087809857?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/5/26/2025-05-26-second-challenge-to-convenience-of-the-employer-rule

This week we look at:

• IRS Reduces Estate Tax Closing Letter Fee
• Tax Court Scope of Review in Passport Cases
• Marital Deduction for Bequests to Trust
• “Reasonable Cause” in Late-Filing Penalty Cases
• “No Tax on Tips Act” (S.129) Passes Senate
• Transfer Pricing in Facebook, Inc. & Subsidiaries v. Commissioner
• Navigating New York’s Convenience Rule: Insights from Matter of Zelinsky

Federal Tax Update: Passthroughs and the One Big Beautiful Bill

https://vimeo.com/1085112388?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/5/18/2025-05-19-passthroughs-and-the-one-big-beautiful-bill

This week we look at:

• IRC Section 7433 and the Scope of the Collection Waiver of Sovereign Immunity
• The Claim of Right Doctrine Applied to Business Errors
• IRC Section 7433: Reinforcing Collection vs. Assessment Distinction
• Selected issues from The One, Big, Beautiful Bill’s tax provisions
• Proposed Changes to the Section 199A Qualified Business Income Deduction
• Proposed Changes Affecting Passthrough Entities and State PTE Taxes
• Interest Deductions and Penalties in Complex Financial Transactions

Federal Tax Update: Taxpayer Fails to Qualify for Deduction for DoD Ordered Move

https://vimeo.com/1083016328?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/5/9/2025-05-12-taxpayer-fails-to-qualify-for-deduction-for-dod-ordered-move

This week we look at:

• Deductibility of IVF and Gestational Surrogacy Costs
• Fraudulent Tax Claims & 28 U.S.C. § 2514
• Tax Collection Suits & Statute of Limitations in United States v. Ragen
• Moving Expense Deduction - Civilian Department of Defense Contractor Eligibility
• Tax Court Jurisdiction - The 90-Day Deadline for Deficiency Petitions

 

Federal Tax Update: Will We See PL 86-272 Finally Revised

https://vimeo.com/1080965698?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/5/2/2025-05-05-will-we-see-pl-86-272-finally-revised

This week we look at:

• ERC Claims Filed Without Schedule R
• Reasonable Cause for Information Return Penalties: Reliance on Software
• Proposed Expansion of P.L. 86-272 "Solicitation of Orders" Definition
• 2026 Inflation Adjustments for HSAs and Excepted Benefit HRAs

Federal Tax Update: Twice to the Supreme Court

https://vimeo.com/1078808516?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/4/25/2025-04-28-twice-to-the-supreme-court

This week we look at:

• Navigating the Overlap: Civil Tax Assessments and Criminal Restitution Orders
• Navigating Innocent Spouse Relief: A Look at Salvi v. Commissioner
• Supreme Court Weighs Tax Court Jurisdiction in Levy Disputes After Tax Payment: A Deep Dive into Commissioner v. Zuch
• Navigating ERISA Prohibited Transaction Claims: Insights from Cunningham v. Cornell University

Federal Tax Update: Hobby Horse Problems

https://vimeo.com/1076802508?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/4/18/2025-04-21-hobby-horse-problems

This week we look at:

• Navigating the 90-Day Deadline for Employment Tax Redeterminations: The Belagio Fine Jewelry, Inc. Case and Equitable Tolling
• GWA, LLC v. Commissioner: Substance Over Form and the Nuances of Tax Elections for Disregarded Entities
• Notice 2025-23: Treasury and IRS Signal Withdrawal of Basis Shifting TOI Regulations and Related Penalties
• Hobby Loss and Failure to File: A Deep Dive into Himmel v. Commissioner

 

Federal Tax Update: A Very Busy Week as the Deadline Approached

https://vimeo.com/1076132850?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/4/16/2025-04-16-a-very-busy-week-as-the-deadline-approached

This week we look at:

• Massachusetts Source Income and the Sale of Stock by Nonresident
• Navigating the Valuation Landscape: Insights from Pierce v. Commissioner
• Personal Liability for Corporate Sales and Use Tax: An Analysis of Matter of the Appeal of B. Wageman
• Navigating the IRS’s ERC Claim Processing Moratorium and "Risking" Procedures
• Jurisdictional Prerequisites in Tax Refund Suits: A Case Study of Estate of Robert F. Armitage, Deceased v. The United States
• Dependency Claims and Child Tax Credits: A Look at Correll v. Commissioner
• WT Art Partnership LP v. Commissioner: Charitable Contribution Deductions and Valuation Pitfalls
• Zajac v. Commissioner: Disallowance of Numerous Deductions and Upholding Penalties
• Hampton v. Commissioner: Public Policy and Disallowance of Shareholder Loss Deduction
• Revised SIFL Rates for Valuation of Noncommercial Flights: Revenue Ruling 2025-9
• IRS Provides Limited Penalty Relief for Certain Micro-Captive Disclosure Statements
• The Demise of DeFi Broker Reporting: An Analysis of H.J. Res. 25

Federal Tax Update: The Cost of Too Good to Be True

https://vimeo.com/1072972311?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/4/6/2025-04-07-the-cost-of-too-good-to-be-true

This week we look at:

• Ranch Springs, LLC v. Commissioner: A Case Study in the Valuation of Conservation Easements and the Pitfalls of Aggressive Tax Planning
• The Duty of Consistency Prevails: A Case Study in Innocent Spouse Relief and Subsequent Asset Claims

Navigating the Murky Waters of Investment Tax Credits and Passive Activity Rules: A Deep Dive into Strieby v. Commissioner

Federal Tax Update: End of Paper Tax Payments and Refund Checks Coming

https://vimeo.com/1070813367?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/3/30/2025-03-31-end-of-paper-tax-payments-and-refund-checks-coming

This week we look at:

• Congress Passes Resolution to Nullify Final Regulations on DeFi Information Reporting in TD 10021
• Interim Final Rule Limiting BOI Filing Requirements Released by Treasury Department
• Substantiating Depreciation for Converted Property: A Look at Smith v. Commissioner
• Executive Order Will Generally Bar the Use of Paper Checks to Make Payments to or Receive Refunds from Treasury, Including Tax Related Ones
• Jones et al. v. Commissioner: A Deep Dive into the Tax Court’s Scrutiny of a Microcaptive Insurance Arrangement
• Navigating Jurisdictional Hurdles in Tax Refund Claims: A Look at Hamilton v. United States
• Ninth Circuit Affirms Willful Failure to Pay Trust Fund Taxes: A Case Study for CPAs