FICPA Podcasts

Federal Tax Update: Estate Tax Problems for Buy Sells Funded by Life Insurance

https://vimeo.com/955638540?share=copy

https://www.currentfederaltaxdevelopments.com/podcasts/2024/6/9/2024-06-10-estate-tax-problems-for-buy-sells-funded-by-life-insurance

This week we look at:

• US Supreme Court rules that a requirement to redeem the decedent’s shares cannot be considered to reduce the value of the entity, but life insurance proceeds received by the entity to fund the buyout will increase the value
• Taxpayer denied relief for late rollover when funds were accidentally transferred from employer plan to Roth IRA
• IRS rules certain payments related to East Palestine, Ohio derailment are §139 disaster payments
• What options exist for an employer with a pending ERC claim?

Federal Tax Update: LLC as an S Corporation Issues

https://vimeo.com/952942911?share=copy

https://www.currentfederaltaxdevelopments.com/podcasts/2024/6/2/2024-06-03-llc-as-an-s-corporation-issue

This week we look at:

• IRS announces that Direct File will continue into 2025 and be expanded while maintaining other program
• A taxpayer finds its not so simple as just file a Form 2553 if you want to have an LLC taxed as an S corporation, but did realize the error fast enough to get a PLR to restore S status

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