FICPA Podcasts

Federal Tax Update: Misleading Silences Are Sometimes Fine in Tax

https://vimeo.com/950819978?share=copy

https://www.currentfederaltaxdevelopments.com/podcasts/2024/5/27/2024-05-27-misleading-silences-are-sometimes-fine-in-tax

This week we look at:

• Yet another PLR requested for missed QSST election after S shares moved to trust following death of a shareholder
• Tax preparer’s conviction for willfully filing false returns upheld on appeal despite his argument he had doing what he did for years
• Letters to taxpayer from IRS Appeals did not extend the time to file suit for a claim for refund
• A partnership had properly elected to use BBA audit provisions early, rendering IRS FPAA invalid

Federal Tax Update: 2024-05-20 ERC Battles Continue

https://vimeo.com/947543909?share=copy

https://www.currentfederaltaxdevelopments.com/podcasts/2024/5/17/2024-05-20-erc-battles-continue

This week we look at:

• DOJ issues proposed rule that would remove cannabis businesses from loss of most business deductions under IRC §280E
• Filing date relief issued for those impacted by Ohio tornadoes from March
• IRS National Fraud Counsel speaks on ERC exams in ABA Tax Section webinar
• Tax adviser files suit to attempt to force the IRS to start processing ERC claims
• Tax Court imposes penalty for raising frivolous claims against taxpayer who argued wages are not income (among other things)

Federal Tax Update: Changes to CAFs and Process for Tax Pros to Obtain Transcripts

https://vimeo.com/945334377?share=copy

https://www.currentfederaltaxdevelopments.com/podcasts/2024/5/12/2024-05-13-changes-to-cafs-and-process-for-tax-pros-to-obtain-transcripts

This week we look at:

• IRS gives update on final results for ERC voluntary compliance program and discusses the future
• The taxpayer’s contract did not make payment contingent on the success of research
• DOJ announces CPA firm barred from promoting CRAT/single premium annuity shelter
• IRS provides information on CAF “under review status” and changes to requesting transcripts

Federal Tax Update: IRS Can Assess Penalties for Failure to File Form 5471 per DC Circuit

https://vimeo.com/943025614?share=copy

https://www.currentfederaltaxdevelopments.com/podcasts 

This week we look at:

• IRS releases Fact Sheet on disaster provisions for retirement accounts added by SECURE 2.0 Act
• DC Circuit reverses Tax Court ruling that IRS does not have assessment authority for failure to file a report under IRC §6038(b) (Form 5471)
• Electric vehicle final regulations issued
• Department of Justice begins process to move marijuana from Schedule I to Schedule III which would cause §280E to no longer limit deductions for cannabis businesses
• Lack of any written records on time President/COO spent on activities or even estimate time spent on qualified research activities doomed attempt to claim a credit under IRC §41(a)

Federal Tax Update: No Minimum Attention Required for Supervisor Approval of Penalties per Tax Court

https://vimeo.com/940427506?share=copy

https://www.currentfederaltaxdevelopments.com/podcasts/2024/4/28/2024-04-29-no-minimum-attention-required-for-supervisor-approval-of-penalties-per-tax-court

This week we look at:

• Final regulations issued on credit transfer provisions of the Inflation Reduction Act
• Tax Court rules the law does mandate a minimum level of attention by a supervisor when approving a proposed penalty
• IRS announces the end of the Direct File pilot and will announce the next steps shortly

Federal Tax Update: IRS Extends Limited RMD Relief But Warns They Expect This to Be the Last Time

https://vimeo.com/937007922?share=copy

https://www.currentfederaltaxdevelopments.com/podcasts/2024/4/20/2024-04-22-irs-extends-limited-rmd-relief-but-warns-they-expect-this-to-be-the-last-time

This week we look at:

• IRS again waives penalties for certain RMD distributions for inherited IRAs and retirement plans, but indicates this should be the last time
• FinCEN adds more Q&As to BOI FAQ for the first time since January

Federal Tax Update: Tax Court Reverses Position on Validity of Conservation Easement Regulation

https://vimeo.com/929341969?share=copy

https://www.currentfederaltaxdevelopments.com/podcasts/2024/3/31/2024-04-01-tax-court-reverses-position-on-validity-of-conservation-easement-regulation 

This week we look at

• Tax Court reverses position on validity of a regulation it had upheld four years ago
• US Supreme Court hears oral arguments in case involving estate tax value of a corporation that received life insurance to redeem the majority shareholder’s estate
• IRS Criminal Investigation Divisions announces update on COVID relief related investigations and convictions

Federal Tax Update: ERC Voluntary Disclosure Program Is Over - What Next

https://vimeo.com/926912400?share=copy

https://www.currentfederaltaxdevelopments.com/podcasts/2024/3/24/2024-03-25-erc-voluntary-disclosure-program-is-over-what-next

This week we look at:

• As ERC voluntary compliance program ended, IRS release discusses agency’s plans going forward
• Senate Finance Chair Wyden indicates there be a cloture vote in the Senate on House passed tax bill
• IRS issues proposed regulations to make SPA CRAT arrangements listed transactions
• IRS asks Supreme Court to overturn Culp decision

Federal Tax Update: Last Call to Enter ERC Voluntary Disclosure Program

https://vimeo.com/924422473?share=copy

https://www.currentfederaltaxdevelopments.com/podcasts/2024/3/17/2024-03-18-last-call-to-enter-erc-voluntary-disclosure-program

This week we look at:

• FinCEN gives formal notice of appeal of CTA BOI case
• Deadline rapidly approaching for entering first ERC voluntary disclosure program
• Arizona lawmakers write the IRS about tax status of 2023 state rebates
• Court of Appeals finds it is barred from hearing appeal of Tax Court dismissal of small case

Federal Tax Update: FinCEN Announces Enforcement Reaction to Alabama Case

https://vimeo.com/921816386?share=copy

https://www.currentfederaltaxdevelopments.com/podcasts/2024/3/10/2024-03-11-fincen-announces-enforcement-reaction-to-alabama-case

This week we look at:

• FinCEN announces position on handling BOI enforcement following National Small Business United v. Yellen
• IRS issues warning about companies peddling “doctor’s notes”
• Tax Court warns taxpayer about litigating an issue the taxpayer had previously litigated and lost on for a prior year