FICPA Podcasts

Federal Tax Update: Senate Finance Committee Tax Provision Draft Issued

https://vimeo.com/1095435474?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/6/22/2025-06-23-senate-finance-committee-tax-provision-draft-issued

This week we look at:

• Schwartz v. Commissioner: The Critical Role of Estimated Tax Compliance in Collection Due Process Determinations
• Cano v. Commissioner: Validity of Notice of Deficiency and Address Errors
• Key Differences Between House and Senate Tax Provisions in Reconciliation Process to Date

Federal Tax Update: The Case of the Vanishing Levy

https://vimeo.com/1093248015?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/6/16/2025-06-16-the-case-of-the-vanishing-levy

This week we look at:

• Understanding Automatic Accounting Method Changes-Revenue Procedure 2025-23
• Accounting Method Changes in Conmac Investments, Inc.
• Conservation Easements in Glade Creek Partners, LLC
• Tax Treaty Exemptions in Kramarenko v. Commissioner
• Tax Refund Litigation & Variance Doctrine in Shleifer v. U.S.
• Tax Court Jurisdiction in Commissioner v. Zuch
• Digital Asset Reporting & Withholding in Notice 2025-33

Federal Tax Update: Worthlessness vs Cancellation of Debt Are Not the Same

https://vimeo.com/1091625670?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/6/8/2025-06-09-worthlessness-vs-cancellation-of-debt-are-not-the-same

This week we look at:

• Navigating Corporate Alternative Minimum Tax (CAMT)
• Conservation Easement Valuation & Penalties: A Warning from Tax Court
• Collection Due Process (CDP) & Offers in Compromise (OICs): Lessons from Tax Court
• Accuracy-Related Penalties: Navigating Negligence and Insufficient Professional Reliance
• Understanding Treasury’s Request for Information on Modernizing Federal Payments
• Worthlessness vs. Discharge: A Ninth Circuit Examination of Bad Debt Deductions Concurrent with COD Income
• Navigating the Religious Exemption Landscape: A Deep Dive into Unemployment Compensation Tax

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