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As a result of the passage of the One, Big, Beautiful Bill Act (OBBBA), 2025 marked a major shift in how millions of American workers report their income and claim deductions. For the first time, tipped workers and overtime earners may receive significant new deductions, even if their employers aren’t yet required to separately track […]

Falling behind on taxes can feel overwhelming, but Illinois is offering taxpayers a second chance. The Illinois Tax Delinquency Amnesty Act of 2025 creates a limited-time opportunity for individuals and businesses to pay off overdue state taxes without having to shoulder the added burden of penalties and interest. By giving taxpayers with outstanding obligations a […]

On October 24, 2024, Commissioner Daniel Werfel announced that the Internal Revenue Service (IRS) would end its practice of automatically assessing penalties for late-filed forms relating to foreign gifts or bequests, effective immediately. Contrary to popular belief, such penalties were frequently assessed against lower-income taxpayers, immigrants, and small businesses. The change in procedure, which relates […]

On December 3, 2024, the US District Court for the Eastern District of Texas found that the Corporate Transparency Act (CTA) was likely unconstitutional and issued a preliminary injunction to that effect. See Top Cop Shop, Inc. vs. Garland, No. 4:24-CV-478 (E.D. Texas 12/3/24). The CTA was enacted in 2021, and was meant to combat […]

In June of 2024, the Internal Revenue Service (IRS) issued guidance attempting to address the perceived inappropriate use of existing partnership rules related to certain related-party basis-shifting transactions. These basis-shifting transactions are intended to generate tax benefits without any meaningful economic substance. IRS exam teams have reported repeated instances of inappropriate basis-shifting practices by related-party […]

On February 21, 2024, the Internal Revenue Service (IRS) announced that it plans to begin dozens of audits on business aircraft involving personal use, contributing to the Inflation Reduction Act’s efforts to improve tax compliance for high-income individuals and businesses. These audits will focus on aircraft usage by large corporations, partnerships, and wealthy taxpayers, and […]

In February of 2020, the United States Tax Court issued a Memo, Railroad Holdings, LLC T.C. Memo. 2020-22 (U.S.T.C. Feb. 5, 2020), and an Order, Rock Creek Holdings, LLC, Tax Court Order, 2/10/2020. Both the Memo and the Order pertain to the conservation easement in dispute in the cases. In the first case, the Court […]

When it comes to the charitable donation of art, the Internal Revenue Service (IRS) has increasingly adopted a predictable strategy, as outlined in part two of this series. Similar to cases involving conservation easements, the IRS can even take the position that donated art is worth $0. While this is the IRS’s most extreme position […]

As discussed in part one of this series on art donations, a taxpayer who wishes to receive a tax deduction for their charitable donation of a work of art should take several steps in anticipation of the Internal Revenue Service’s (IRS’s) refusal to allow the deduction. In recent years, especially, the IRS has undertaken a […]

Among the many ways that Congress uses tax laws to influence taxpayers’ spending, encouraging donations to charitable causes is perhaps the least controversial. Section 170 of Title 26 of U.S. Code, for example, has outlined Internal Revenue Service (IRS) policy on charitable contributions and gifts for decades. For many taxpayers, such donations include small payments […]