Current Federal Tax Developments

Hosted by Edward Zollars, CPA

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100

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Aug 2026

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EN-US

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Weekly update on federal income tax developments

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August 23, 2026

2026-08-24 Proposed Regulations Week

This week we look at: Form 1041-A Relief for Passthrough Charitable Deductions (REG-109082-25) Vested Development Rights & Easement Valuation — Malibu Valley Land v. Commissioner First Circuit Bars Equitable Tolling of Section 6213(a) — Kyick Holdings v. Commissioner PRWORA Immigration Restrictions on Refundable Credits (REG-119882-25) Single-Employer DB Pension Funding Proposed Regulations (REG-107855-25) Excluded Property Sales Income Under Section 250 (REG-117130-25) Section 163(j) Business Interest Limitation Update — Fact Sheet FS-2026-14 Doug LaMalfa Federal Disaster Tax Relief Certainty Act (H.R. 5366) IRS Ends Uniform Easement Settlement Initiative, Creates Office of Conservation Easements Trump Account Eligible Investment Rules — Proposed Regulations (RIN 1545-BS14) An audio only version of this week’s update can be streamed or downloaded below: 2026-08-24 Proposed Regulations Week Edward K. Zollars, CPA (Arizona) Download This week’s update articles and broadcast slides can be downloaded below; 2026-08-24 Current Federal Tax Developments 2026-08-24 Slides

August 16, 2026

2026-08-17 Maybe State Law Limited Partner Isn't the Test for 1402(a)(13)

This week we look at: Unpacking the Saver’s Match: Technical Guidance and Operational Frameworks Under Notice 2026-48 Harmonizing Section 3406 Backup Withholding with Section 6050W De Minimis Reporting Thresholds The High Bar for Equitable Tolling in Tax Practice: The Eighth Circuit’s Final Ruling in Boechler, P.C. Employer Contributions to Trump Accounts and Nondiscrimination Rules under REG-101355-26 The Perpetual Burden of Carryover Substantiation: AMT Credits and Recordkeeping in Beacom v. Commissioner Equitable Tolling of Tax Court Filing Deadlines: Maniktala v. Commissioner (8th Cir.) Standardizing Retirement Plan Rollovers and Trustee-to-Trustee Transfers under SECURE 2.0: Notice 2026-49 Unmasking the $70 Million Dubai Fraud: Section 165 Theft Loss Deductions in Deutsch v. Commissioner Treasury Proposes Substantive Section 987 Relief for Controlled Foreign Corporations (REG-103844-26) Rehearing Reversal: The Fifth Circuit’s Management Test for the Limited Partner Exception (K Alain, L.L.L.P.) The Crucial Role of Highest and Best Use in Conservation Easement Valuations: Evans v. Commissioner 2026-08-17 Maybe State Law Limited Partner Isn't the Test for 1402(a)(13) Edward K. Zollars, CPA (Arizona) Download You can download PDFs with copies of this week’s articles and slides below: 2026-08-17 Slides 2026-08-17 CFTD Articles

August 9, 2026

2026-08-10 IRS Guidance on Qualifed Overtime for 2026-2028

This week we look at: Transitioning Foreign Tax Allocations and Implementing the Ten Percent Credit Disallowance Under Section 960(d)(4) Trustee-to-Trustee Transfers of Inherited IRAs Through an Estate: Technical Analysis of PLR 202631001 Federal Courts Lack APA Jurisdiction Over Foreign Gift Penalty Disputes: The Adequate Alternative Remedy Barrier Sourcing Executive Termination Payments: Analyzing the Bifurcated Sourcing of Severance and RSUs in the Appeal of Otting The Permanent Section 45S Paid Family and Medical Leave Credit: Analyzing the Statutory Wage Method Mechanics and the New Premium Method Under Notice 2026-28 The Tax Court Open Door: Why the BBA Partnership Petition Deadline Is Not Jurisdictional Commingled Funds, Unsubstantiated Deductions, and the Binding Form of Transactions: A Technical Tax Analysis of Reed v. Commissioner The Safe Harbor That Wasn’t: Deconstructing the Anti-Abuse Rule in SIH Partners LLLP v. Commissioner The Evolution of Qualified Overtime Compensation Deductions: Analyzing IRS Fact Sheet FS-2026-13 and Its Practical Implications An audio only version of this week’s broadcast can be streamed or downloaded below: 2026-08-10 IRS Guidance on Qualified Overtime for 2026-2028 Edward K. Zollars, CPA (Arizona) Download This week’s articles can be downloaded below: 2026-08-10 Current Federal Tax Developments

August 2, 2026

2026-08-03 On Again Off Again On Again PLR

This week we look at: IRS Reinstates Tax Deferral on Variable Annuity Term Certain Options: Reconsideration and Reversal in PLR 202630002 Understanding the ERC Pleading Standard: Federal Claims Court Deferral in I Health and Life Insurance Services Predecessor Losses, the Lonely Parent Rule, and the Limits of Economic Reality: Analysis of HBM Holdings Co. v. Commissioner Double Books and Disguised Payees: Corporate Personal Expenses and the Civil Fraud Penalty in Prezioso v. Commissioner An audio only version of this week’s broadcast can be streamed or downloaded below: 2026-08-03 On Again Off Again On Again PLR Edward K. Zollars, CPA (Arizona) Download The articles for this week’s update can be downloaded as a PDF below: Current Federal Tax Developments August 3, 2026

July 26, 2026

2026-07-27 AICPA New Interpretation on Indepdendence and Tax Engagements

This week we look at: Valuation of Remainder Interest Gifts Upon Trust Termination: State Law and Net Gift Adjustments in Lewis v. Commissioner Revenue Procedure 2026-26: Technical Overview of 2027 Indexing Adjustments for Premium Tax Credits and Affordability Standards Limitations of Interest Abatement Claims Under I.R.C. § 6404(e)(1) in the Context of ERC-Driven Amendments Section 6015(c) Relief and the Substantiation Trap: An Analysis of Anderson v. Commissioner Navigating the AICPA’s New Tax Services Independence Standards: A Guide for Practitioners An audio only version of this week’s broadcast can be downloaded or streamed below: 2026-07-27 AICPA New Interpretation on Independence and Tax Engagements Edward K. Zollars, CPA (Arizona) Download Articles on each update and a copy of the slides for this week can be downloaded as a PDF below: Current Federal Tax Developments July 27, 2026 Articles Presentation Slides

July 19, 2026

2026-07-20 IRS Expands Business Tax Accounts

This week we look at: Partnership Recourse Rules: Conditional DROs will not establish EROL under § 1.752-2. Mileage Rate Adjustment: Business standard mileage rate rises to 76 cents on July 1, 2026. Business Tax Account: Modernized self-service portal expands features but requires active annual maintenance. Litigation Legal Fees: FCRA settlements are taxable gross income without above-the-line deduction. Corporate Reorganizations: Tax Court invalidates regulation limiting 100% DRD in post-Loper Bright era. ERC Litigation Realities: Exhaustion loophole rejected; notice pleading standards approved in refund suits. Conservation Easements: Valuation must be grounded in immediate local market demand, not speculation. An audio only version of this week’s broadcast can be streamed or downloaded below. 2026-07-20 IRS Expands Business Tax Accounts Edward K. Zollars, CPA (Arizona) Download You can download a PDF with articles for this week’s update and a copy of this week’s slides. Current Federal Tax Developments July 20, 2026 Slides

July 12, 2026

2026-07-13 A Week of Final Regulations

This week we look at: Transitioning from First Time Abate (FTA) to Automatic Exemption from Penalty (AEP) Strict Enforcement of Tax Refund Statutes of Limitations Employee Retention Credit (ERC) Refund Claims & Pleading Standards Pandemic-Era Persistence of New York's Convenience of the Employer Rule Invalidity of Treasury Regulation Section 1.951A-2(c)(5) Non-Shareholder Capital Contributions vs. Compensation Final Section 1035 Exchange & Corporate Reorganization Regulations Reclassification of Abusive CRAT Structures as Listed Transactions The National Taxpayer Advocate’s Perspective on AEP An audio only version of this week’s broadcast can be downloaded or streamed below. 2026-07-13 A Week of Final Regulations Edward K. Zollars, CPA (Arizona) Download PDFs of the articles for this week’s update and the slides can be downloaded below: 2026-07-13 Current Federal Tax Developments Slides

July 12, 2026

2026-06-22 Qualified Opportunity Zone Interim Guidance for OBBBA

This week we look at: Relief from Ineffective S Corporation and QSub Elections Procedural and Jurisdictional Limits in Challenging IRS Guidance Medicaid Gross Receipts, Cohan Estimations, and Professional Reliance Standards and Deceit in Supervised Release Transitional Guidance on Qualified Opportunity Zones An audio version of this week’s broadcast can be downloaded or streamed below: 2026-06-22 Qualified Opportunity Zone Interim Guidance for OBBBA Edward K. Zollars, CPA (Arizona) Download Articles for this week’s broadcast and copies of slides can be downloaded below: Current Federal Tax Developments June 22, 2026 Slides June 22, 2026

July 5, 2026

2026-07-06 ERC Cases Galore Week

This week we look at: Section 7508A(d) and Interest on Pre-COVID-19 Disaster Tax Deficiencies The Soroban Capital Partners SECA Tax Controversy Pleading Requirements for the Employee Retention Credit (Tapestry Senior Housing) ERC Causation and the Essential Business Hurdle (RAAM Construction) The Section 530A Transfer Tax Safe Harbor (Rev. Proc. 2026-25) Penalty Supervisory Approval Verification in CDP (Besicorp Group) Retroactive ERC Deadlines & Constitutional Challenges An audio only version of this week’s broadcast can be streamed or downloaded below: 2026-07-06 ERC Cases Galore Week Edward K. Zollars, CPA (Arizona) Download You can download a copy of the stories for this week’s updates and the slides for this week from the link below: Current Federal Tax Developments July 6, 2026 Articles July 6, 2026 Slides

June 28, 2026

2026-06-29 OPR Releases Guidance On use of Generative AI

This week we look at; Nominal S Corporation Ownership and the Abuse Exception Recapping the ERC via Section 7405 Civil Actions Constructive Dividends, Formalities, and Civil Fraud CDP Hearings, Offer-In-Compromise, and RCP Calculations Professional Responsibility and Responsible AI Use Rigorous Proof for ERC "Partial Suspension" Claims An audio only version of this week’s broadcast can be downloaded or streamed below. 2026-06-29 OPR Releases Guidance on Use of Generative AI Edward K. Zollars, CPA (Arizona) Download PDFs with this week’s articles on the updates and the slides used for this week’s presentation can be downloaded below. Current Development Articles Slides for Presentation