
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 Un...
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Federal Tax Update Podcast Series

This week we look at: IRS Reinstates Tax Deferral on Variable Annuity Term Certain Options: Reconsideration and Reversal in PLR 202630002 Un...

This week we look at: Valuation of Remainder Interest Gifts Upon Trust Termination: State Law and Net Gift Adjustments in Lewis v. Commissio...

This week we look at: Partnership Recourse Rules: Conditional DROs will not establish EROL under § 1.752-2. Mileage Rate Adjustment: Busines...

This week we look at: Transitioning from First Time Abate (FTA) to Automatic Exemption from Penalty (AEP) Strict Enforcement of Tax Refund S...

This week we look at: Section 7508A(d) and Interest on Pre-COVID-19 Disaster Tax Deficiencies The Soroban Capital Partners SECA Tax Controve...

This week we look at: Nominal S Corporation Ownership and the Abuse Exception Recapping the ERC via Section 7405 Civil Actions Constructive...

This week we look at: Relief from Ineffective S Corporation and QSub Elections Procedural and Jurisdictional Limits in Challenging IRS Guida...

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...

This week we look at: Proposed Increase to Estate Tax Closing Letter User Fee Divergent Causation Standards for ERC Eligibility Valuation Ex...

This week we look at: Procedural Timeliness & Automatic Extensions Spousal IRA Rollovers Through Estates and Trusts Collateral Estoppel and...

This week we look at: Equitable Relief for Erroneous Tax Refunds: An Analysis of the Fourth Circuit's Reversal in LaRosa v. Commissioner Fin...

This week we look at: Technical Analysis of the Proposed Regulations Establishing Excepted Fertility Benefits Analysis of the IRS Time-Limit...

This week we look at: Syndicated Conservation Easements and the Valuation Conundrum: An Analysis of T.C. Memo. 2026-36 Analysis of Garcia-Ro...

This week we look at: Reasonable Cause Relief Under the Small-Corporation Provision for Form 5472 Penalties Extending the Statute of Limitat...

This week we look at: Tax Implications of the Rescheduling of State-Licensed Medical Marijuana Disallowance of COVID-19 Leave Credits: A Rev...

This week we look at: A Technical Analysis of the Final Section 224 Regulations on the Qualified Tip Deduction Analysis of Proposed Regulati...

This week we look at: Corporate Capacity and State Law Revivor Digital Asset Identification Relief Interest and Bonus Depreciation Relief ER...

This week we look at: Proposed Regulations for IRC Section 530A "Trump Accounts" IRC Section 6434 Trump Account Pilot Program Micro-Captive...

This week we look at: Fiduciary and Beneficiary Liability for Unpaid Estate Taxes Retroactive Entity Classification and Partnership Basis 20...

This week we look at: Required Minimum Distribution Regulations Delay CDP Proceedings and Underlying Liabilities Section 743(b) Adjustments...