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Proposed Removal of a Reporting Requirement for Trusts Whose Charitable Contribution Deductions are Solely for Contributions Made by Passthrough Entities, REG-109082-25, 91 Fed. Reg. _____ (proposed Aug. 17, 2026)
The Department of the Treasury and the Internal Revenue Service (IRS) have issued a notice of proposed rulemaking, REG-109082-25, designed to stream...
Evans v. Commissioner, Nos. 24-11882 & 24-11884 (11th Cir. 2026)
For tax professionals advising clients on charitable contributions of real property, conservation easements represent one of the most highly scrutinized areas of federal tax law. The critical battlefield in these cases is almost invariably the valuation of the easement. In the consolidated ap...
K Alain, L.L.L.P. v. Commissioner of Internal Revenue, No. 24-60240, --- F.4th --- (5th Cir. Aug. 12, 2026), withdrawing and substituting for Sirius Solutions, L.L.L.P. v. Commissioner of Internal Revenue, 165 F.4th 374 (5th Cir. Jan. 16, 2026), vacating and remanding Nos. 11587-20 and 30118-21 (T.C. Feb. 20, 2024)
On August 12, 2026, the Uni...
Foreign Currency Gain or Loss of Controlled Foreign Corporations, REG-103844-26, 91 Fed. Reg. (proposed Aug. 14, 2026)
On August 13, 2026, the Department of the Treasury and the Internal Revenue Service (IRS) released a significant notice of proposed rulemaking under Internal Revenue Code (IRC) Section 987. The proposed regulations introduce a highly anticipat...
Deutsch v. Commissioner, T.C. Memo. 2026-66, August 12, 2026
For tax professionals representing clients who have fallen victim to fraudulent investment schemes, securing a theft loss deduction under Internal Revenue Code (IRC) Section 165 is a highly technical and fact-intensive endeavor. The recent decision in Deutsch v. Commissioner, T.C. Memo. 2026...