Federal Tax Update Podcast

Hosted by The Ohio Society of CPAs

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100

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Aug 2026

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Federal Tax Update Podcast Series

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August 16, 20261 hr 49 min

2026-08-17 Maybe State Law Limited Partner Isn't the Test for 1402a13

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

August 2, 202649 min

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

July 26, 20261 hr 8 min

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

July 19, 202651 min

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.

July 12, 20261 hr 25 min

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

July 5, 20261 hr 47 min

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

June 28, 20261 hr 20 min

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

June 19, 202657 min

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

June 12, 20261 hr 3 min

2026-06-15 Trusts and the New Section 68

This week we look at: Application of New Section 68 to Trusts and Estates Assessing the Risks of Hindsight in Late § 475(f)(1) Elections The Eradication of the 5% Safe Harbor (Clean Energy) Limits of § 2036(a) and Tax-Motivated Transfers Section 183 Hobby Losses & Penalties New Section 25F Education Freedom Tax Credit

June 7, 20261 hr 6 min

2026-06-08 An Inconsistent Tale of Two ERC Court Rulings

This week we look at: Proposed Increase to Estate Tax Closing Letter User Fee Divergent Causation Standards for ERC Eligibility Valuation Extremes in Conservation Easements Substantiating Mortgage Interest Deductions Taxation of Cryptocurrency Staking Rewards Section 4960 and "Covered Employees" FBAR Compliance and IRS Agent Authority

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