FICPA Podcasts FICPA Podcasts

https://vimeo.com/966201086?share=copy
https://www.currentfederaltaxdevelopments.com/podcasts/2024/6/23/2024-06-24-supreme-court-upholds-the-965-transition-tax
This week we look at:
The Supreme Court rules, in a more divided than it may appear opinion, that the §965 transition tax is Constitutional, sustaining the result from the Ninth Circuit in the Moore case.
IRS gives interim guidance for special distribution relief in the SECURE Act 2.0 for certain distributions.
IRS indicates it will now be (slowly) processing ERC claims, vast majority show issues

https://vimeo.com/959844883?share=copy
https://www.currentfederaltaxdevelopments.com/podcasts/2024/6/16/2024-06-17-do-not-believe-your-chatbot-on-tax-matters
This week we look at:
IRS provides last minute relief for payment of second quarter corporate estimated tax payments related to corporate alternative minimum tax
En-banc rehearing request denied in case of Farhy v. Commissioner by DC Circuit
CPA pleads guilty to tax charges related to syndicated conservation easement program
Taxpayer Advocate warns of relying on generative AI for answering tax questions for consumer tax software - and there are just as big of issues for tax professionals

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?

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

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

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)