On September 28, 2026, Treasury and the IRS issued Revenue Ruling 2026-20 and Notice 2026-62. Together they address Section 351/ETF conversions, ETFs’ use of in-kind redemptions to avoid income and non-qualifying income recognition, and investment funds’ strained reading of technical rules to generate taxpayer-favorable capital gains and ordinary losses. Michael Scott once shouted “I declare bankruptcy!” and assumed that his words controlled. Some advisors took a similar approach to Section 351/ETF conversion structures. The IRS has now made clear that announcing…More

On September 10, 2026, the Treasury Department and IRS issued proposed regulations implementing key provisions of the One Big Beautiful Bill Act (OBBBA) related to qualified opportunity zones (QOZs) and qualified opportunity funds (QOFs). For opportunity zone advisors, these proposed rules mark a pivotal step in the compliance landscape that demands immediate attention. What the Proposed Regulations Cover The proposed regulations address several critical areas for QOZs. First, they clarify that a QOF’s annual information return under the new OBBBA requirements…More

New Trial Cities, Broader Access, and a Pilot of a Smarter Calendar On September 8, 2026, Chief Judge Urda announced three significant changes to how the United States Tax Court administers its trial sessions. Here is what you need to know: Five New Places of Trial The Tax Court has added five new cities as places of trial, bringing the total number of potential trial locations nationwide to 79.  The new locations are: Austin, Texas Charlotte, North Carolina Newark, New Jersey Orlando, Florida Sacramento, California The Court used information…More

On September 4, 2026, the IRS and Treasury Department published proposed regulations (REG-119986-25) that would redefine the nondiscrimination standards every tax-exempt private school must meet under section 501(c)(3). If finalized, these rules could require meaningful changes to admissions policies, scholarship programs, endowments, and donor agreements at schools across the country. The regulations would apply to private primary, secondary, preparatory, or high schools, as well as colleges and universities for taxable years beginning after May 31, 2027. These are…More

If you own a business or reside in Lancaster County, pay close attention: the IRS confirmed in a July 21, 2026 letter that 20 revenue officers will be conducting face-to-face visits with taxpayers in the community during the weeks of August 10 and August 17, 2026. Recent reporting confirmed the IRS sent similar letters to police departments in Millersville Borough, East Cocalico Township, and Lititz Borough. The Millersville Borough Police Department indicated that the IRS visits are part…More

In Big Apple Tompkins Realty LLC v. Commissioner, the Tax Court addressed a question of first impression: whether I.R.C. § 6234(a)’s 90-day petition filing deadline for partnerships subject to the Bipartisan Budget Act of 2015 (BBA) audit rules is jurisdictional.  The IRS argued the deadline is jurisdiction, the Taxpayer said otherwise.  Channeling its inner Bill Lumbergh, the IRS told the Taxpayer, “Yeah ... I’m gonna need you to go ahead and have that petition filed by the deadline.” But the…More

Get your popcorn ready because there is nothing more exciting than the intersection of sports and tax! As a former Division II athlete, the current state of college sports and Name, Image, and Likeness (NIL) deals is fascinating.  Student-athletes typically focus on maintaining good grades, practicing hard, and playing to the best of their abilities, but the Internal Revenue Code (Code) is unlike any playbook they’ve ever seen. Based on a recent hearing, it appears that Congress is aware of…More

Every January, businesses race to issue Forms W-2, 1099, and 1099-NEC, but a small typo in a Social Security Number (SSN) or Taxpayer Identification Number (TIN) can turn into a surprisingly expensive sequel. The IRS requires information returns to include a correct name/TIN combination. If the name doesn’t match the TIN — or the TIN is missing entirely — the IRS can assess substantial penalties and interest. Given the current administration’s focus on illegal immigration, it is imperative that businesses…More

Classroom participation points may boost a child’s grade in history class, but merely raising your hand won’t get you far with the IRS.  The passive activity loss rules under I.R.C. § 469 can make a real economic loss feel like a tax detention: present on the books, but not allowed as a deduction against active income.  For CPAs and tax advisors, the issue is often not whether there was a loss or the amount, but more whether the taxpayer accrued enough…More

On July 1, 2026 the IRS unveiled a new portal for Kwong related refund claims. Taxpayers who want file Forms 843 claiming a refund for interest or penalties that accrued between January 20, 2020 and July 10, 2023 can file claims electronically through the IRS portal. Taxpayers can still paper file Forms 843 through normal refund claim procedures. The IRS clarifies that the portal is only for claims related to fully paid interest or penalties. That means taxpayers who are protectively…More