FICPA Podcasts

Federal Tax Update: Better Late Than Never R&E Procedural Relief

https://vimeo.com/1114518395?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/9/1/2025-09-02-better-late-than-never-rampe-procedural-relief

This week we look at:

• Federal Circuit Ruling Finds Limits on Executive Authority to Impose Tariffs Under IEEPA
• Introduction to OBBBA R&E Expenditure Procedures
• Sixth Circuit Realigns on Tax Court Jurisdiction
• Innocent Spouse Relief: Walsh v. Commissioner Overview
• Taxpayer Precluded from Challenging Liability: Sullivan v. Commissioner
• 60-Day IRA Rollover Waiver in a Fraud Scenario

Federal Tax Update: Stump the LLM

https://vimeo.com/1112554072?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/8/24/2025-08-25-stump-the-llm

This week we look at:

• Federal Complaint Seeking ERC Refunds: Superior Pediatric Care v. United States
• Proposed Revisions to Partnership Information Reporting for Sales or Exchanges of Interests—Form 8308
• Taxation of Unsolicited Stock Transfers: Analysis of Feige v. Commissioner
• Third-Party Intent and the Indefinite Assessment Period: An Analysis of Murrin v. Commissioner
• The One, Big, Beautiful Bill Act (OBBBA): New Deductions & Energy Credit Modifications
• LLM Limitations in Tax Law: Beyond Memorization

Federal Tax Update: State Tax Credit SALT Workaround Regulation Challenge Fails

https://vimeo.com/1110565833?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/8/17/2025-08-18-state-tax-credit-salt-workaround-regulation-challenge-fails

This week we look at:

• Denham Outlines Its Criticisms of the Tax Court’s Use of the Functional Analysis Test for Limited Partners with the First Circuit Court of Appeals
• Disguised Sales and Sham Partnerships: A Comprehensive Review of PICCIRC, LLC v. Commissioner
• Judicial Examination of State Charitable Tax Credit Programs and Federal Deductibility
• The Second Circuit Clarifies Tax Court Filing Deadlines: Implications for Practitioners
• Understanding New Clean Electricity Credit Termination Rules Impact of IRS Notice 2025-42 on Wind and Solar Facilities

 

Federal Tax Update: IRS Announces No Payroll Changes for 2025

https://vimeo.com/1108856952?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/8/10/2025-08-11-irs-announces-no-payroll-changes-for-2025

This week we look at:

• Urgent Guidance Requested on Section 174A Domestic Research and Experimental Expenditures
• Post-Referral Authority in Tax Litigation—IRS Lacked Authority to Approve ERC Refund
• Closer This Time, But Still Not Quite There—Another Microcaptive Loss for the Taxpayers
• Proposed Amendments to IRC Section 132 Fringe Benefit Rules: Switching to NAICS
• Understanding Passthrough Losses and Bankruptcy in Field Attorney Advice 20253101F
• Proactive Engagement with the Office of Professional Responsibility
• IRS Announces Policy for the One Big Beautiful Bill Act for 2025 Payroll Issues

Federal Tax Update: A Late Tax Season Start Expected

https://vimeo.com/1106717036?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/8/2/2025-08-04-a-late-tax-season-start-expected

This week we look at:

• Filing Season Forecast to Start in Mid-February in the Coming Season
• Settlement Proceeds Found to Be Taxable and Taxpayer Stuck With Late-Filing Penalties
• IRS Issues Relief for Certain Issues Related to Partnership Investments and the Corporate Alternative Minimum Tax
• Corporate Mergers and the Same Taxpayer Rule for Interest Netting
• What Is an Educational Organization for Unrelated Business Income Tax (UBIT) Purposes?
• Another Microcaptive Arrangement Falls Under Court Challenge
• Taxpayer’s Claim She Didn’t Consent to the Filing of a Joint Return Didn’t Impact Denial of Innocent Spouse Relief

Federal Tax Update: Dealing with Uncashed Retirement Plan Checks

https://vimeo.com/1102786771?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/7/19/2025-07-21-dealing-with-uncashed-retirement-plan-checks

This week we look at:

• Conservation Easement Deductions: A Critical Review of Rock Cliff Reserve, LLC
• Portability Election Pitfalls: A Deep Dive into Estate of Rowland and DSUE Requirements
• Understanding Equitable Tolling in Tax Court: Insights from Boechler, P.C. v. Commissioner
• A Critical Review of Veribest Vesta, LLC v. Commissioner of Internal Revenue: Implications for Conservation Easement Valuations
• Understanding Withholding and Reporting for Uncashed Retirement Plan Distribution Checks: A Review of Rev. Rul. 2025-15
• Fifth Circuit Affirms Tax Court’s Disallowance of Micro-Captive Insurance Deductions: An Analysis of Swift v. Commissioner

 

Federal Tax Update: Passage of a Much Shorter Additional Tax Bill

https://vimeo.com/1101222681?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/7/14/2025-07-14-passage-of-a-much-shorter-additional-tax-bill

This week we look at:

• Recent Developments: Interpreting the Johnson Amendment in Tax-Exempt Status Litigation
• An Examination of Contract Formation in Tax Court Settlement: Insights from Arden Row Assets, LLC
• Jurisdictional Imperatives in Tax Court: A Case Study on Timeliness and Last Known Address
• Expanding Horizons: Potential Changes to Disaster Tax Relief Under the Filing Relief for Natural Disasters Act

Federal Tax Update: Win Some Lose Some on Statutes of Limitations for the IRS

https://vimeo.com/1098877895?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/7/7/2025-07-07-win-some-lose-some-on-statutes-of-limitations-for-the-irs

This week we look at:

• Bad Debt Deduction and Accuracy-Related Penalties: Key Takeaways from Anaheim Arena Management, LLC v Commissioner
• FBAR Compliance and the CPA’s Due Diligence Under Circular 230
• Dissecting Partnership Audit Limitations: Insights from JM Assets, LP v. Commissioner
• Decoding Penalty Assessments: A Deep Dive into Moxon Corporation v. Commissioner
• Tax Court Scrutiny: Upholding Civil Fraud Penalties in Beleiu v. Commissioner

 

Federal Tax Update: ERC Issues Return to Court

https://vimeo.com/1097540797?share=copy#t=0

https://www.currentfederaltaxdevelopments.com/podcasts/2025/6/30/2025-06-30-erc-issues-return-to-court

This week we look at:

• Court Upholds IRS’s Employee Retention Credit Guidance
• Taxpayer Files in US District Court as the IRS’s Failure to Act on its Appeal Was Causing the Statute of Limitations to Run Out
• IRS Updates K-2 and K-3 Filing Requirements FAQ, Expands Exceptions to Filing
• Taxpayer Advocate Releases Fiscal Year 2026 Objectives Report to Congress
• Trust Fund Recovery Penalties: A Case Study on "Responsible Person" and "Willfulness" Under 26 U.S.C. § 6672

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