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Current Federal Tax Developments

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Zhang v. Internal Revenue Service, No. 26-cv-00525-VKD (N.D. Cal. July 30, 2026)

The compliance burden for U.S. taxpayers receiving foreign gifts has intensified over the last decade, particularly under the disclosure regime mandated by Internal Revenue Code (IRC) § 6039F. Under this section, U.S. persons who receive aggregate foreign gifts exceeding $10,000 (adjuste...


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PLR 202631001, July 31, 2026

For tax practitioners managing estate administrations, the post-mortem division of individual retirement accounts (IRAs) represents a significant compliance challenge. In Private Letter Ruling 202631001, the Internal Revenue Service (IRS) addressed a critical question: whether a trustee-to-trustee transfer of a decedent’s traditional and ...


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Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance, REG-115145-25, July 31, 2026

The Department of the Treasury and the Internal Revenue Service have issued proposed regulations under REG-115145-25 (RIN 1545-BR76) addressing two critical statutory changes introduced by the One, Big, Beautiful Bill Act (OB...


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Walter D. Prezioso & Kimberly J. Prezioso v. Commissioner, T.C. Memo. 2026-63, July 28, 2026

The taxpayer, Walter D. Prezioso, joined GSP Precision, Inc. (GSP)—an aerospace manufacturing company incorporated under California law in 1983 by his father, Juan Pablo Prezioso, and George J. Gottardi—as an employee in 1992. Following Walter’s acquisition of a 25% inter...


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HBM Holdings Co. v. Commissioner, 167 T.C. No. 6 (July 27, 2026)

The United States Tax Court recently issued a reported decision in HBM Holdings Co. v. Commissioner, 167 T.C. No. 6 (2026), providing critical guidance on the intersection of Section 381 corporate liquidations, the "lonely parent" exception, and the Separate Return Limitation Year (SRLY) subgro...


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