1502-75(a)(1), the regulation governing elections to file consolidated federal income tax returns for affiliated groups. The relief was conditioned on the group’s tax liability not being lower than if the election had been timely made.
The IRS granted a partnership a 120-day extension to retroactively file a § 754 election after the partnership missed the deadline due to an inadvertent oversight.
The IRS has approved a taxpayer’s revised schedule of ruling amounts for a nuclear decommissioning reserve fund under § 468A(d)(1), allowing a formula-based approach to calculate annual contributions while ensuring compliance with the statute’s strict timelines.
The IRS granted a taxpayer an extension of time to file a revised schedule of ruling amounts under Section 468A(d)(1), which governs nuclear decommissioning reserve funds, after the taxpayer demonstrated that intervening events beyond its control—specifically a delayed...
The IRS has approved a taxpayer’s revised schedule of ruling amounts under § 468A(d)(1), which governs the maximum deductible contributions to a Nuclear Decommissioning Reserve Fund (NDRF).
468A-3(f)(1)(iv). 9100-3 after failing to meet the 90-day deadline following the NRC’s license renewal. Without the extension, the taxpayer risked disallowance of deductible contributions to its nuclear decommissioning fund, potentially jeopardizing millions in tax deductions.
-sourced income other than earnings directly tied to World Cup participation. S. financial footprint is limited to tournament-related revenue. S. income is confined to World Cup-related activities. By amplifying Rev. Proc.
S. Tax Court took up the case of SIH Partners LLLP v. Commissioner (Docket No. 10099-20, filed August 6, 2026). 6 million foreign tax credit (FTC) denied—all stemming from a single 2012 partnership tax year.
The stakes could not have been higher when the U.S. Tax Court, in a landmark ruling issued August 5, 2026, denied the IRS’s motion to dismiss a Staten Island LLC’s untimely petition—preserving the partnership’s right to challenge a $105,093 tax liability stemming from a Final...
In Reed v. C. Memo. 2026-64 (Aug. 5, 2026), Judge Toro delivered a sweeping rebuke to Scott L. Reed and Stacy N. 2 million for tax years 2012 through 2015.
9100-3 of the Procedure and Administration Regulations to an estate seeking a portability election under § 2010(c)(5)(A) of the Internal Revenue Code.
The IRS has approved a tax-free transfer of surplus pension assets to a defined contribution plan, ruling that at least 25% of the surplus could be moved to a 401(k) without triggering income inclusion, deduction disallowance, or the 50% excise tax under Section 4980 of the Internal Revenue Code.
9100-3 for a surviving spouse to make a late portability election under § 2010(c)(5)(A), allowing the estate to transfer the deceased spouse’s unused exclusion (DSUE) amount.
9100-3, allowing the election to be effective as of Date 5. The taxpayer had requested relief after missing the deadline to file Form 8869, the IRS form required to elect QSub status under § 1361(b)(3).
The IRS granted a 120-day extension to an LLC that missed its deadline to file Form 8832, the Entity Classification Election, allowing it to retroactively elect corporate tax treatment. The relief came under Treas. Reg.
The IRS granted a 60-day extension to a taxpayer seeking to self-certify as a Qualified Opportunity Fund (QOF) under § 1400Z-2(d), resolving a late election caused by an accounting firm’s failure to file Form 8996 with the taxpayer’s partnership return.
The IRS ruled in PLR-115104-25 (April 17, 2026) that County C’s deferred compensation plan qualifies as an eligible § 457(b) plan, allowing participants to defer taxes on contributions until distribution.
The IRS issued a non-precedential Private Letter Ruling (PLR-102725-26) granting tax-free treatment under Section 355 and Section 368 for an S corporation’s spin-off of a subsidiary.
The IRS has issued a private letter ruling (PLR-102620-26) confirming that estate beneficiaries may split inherited IRAs into separate accounts via trustee-to-trustee transfers without triggering taxable distributions or rollovers.
The August 3, 2026 edition of the Internal Revenue Bulletin (IRB 2026–32) delivers a series of consequential updates spanning professional discipline, estate tax planning, pension funding mechanics, wage reporting, and interest rate benchmarks.
S. Tax Court has delivered a decisive blow to Walter D. ’s corporate books. C. Memo.
The Tax Court has delivered a stark reminder to retirees: Social Security benefits are taxable income, and failing to report them can cost thousands. In Charmaine A. Gray v. C. Memo.
The Tax Court’s July 27, 2026, memorandum opinion in Lawrence Hubbard v. C. Memo. 2026-62) delivers a clear message: when the IRS builds its case on third-party documentation like Form 1099-G, taxpayers face an uphill battle.
In a 2026 Tax Court ruling (HBM Holdings LLC v. C. Memo. 2026-12), the court denied HBM Holdings’ attempt to use $108 million in Delavau Holdings’ net operating loss (NOL) carryovers to offset $30 million in taxable income for its consolidated group.
S. 6 million blow to HBM Holdings Company, denying its motion for partial summary judgment and affirming the IRS’s position that the company could not use net operating loss carryovers from Delavau’s deemed liquidation to offset consolidated income.
A publicly traded corporation faced potential disallowance of $2 million in deductions after its tax return preparer omitted a required election statement for capitalizing success-based fees under Rev. Proc. 2011-29.
The IRS granted a 120-day extension under § 2642(g) of the Internal Revenue Code to a taxpayer who inadvertently omitted a $5 million GST exemption allocation on a 2025 gift tax return.
9100-3 to a taxpayer seeking relief for a late Form 8996 filing, allowing it to self-certify as a Qualified Opportunity Fund (QOF) retroactive to Month 1.
A deceased taxpayer’s estate faced a $250,000+ tax liability after failing to report cancellation of debt income (CODI) from a partnership’s discharged indebtedness.
The IRS granted a 120-day extension to an LLC seeking relief for late filings of both Form 8832 (entity classification election) and Form 2553 (S corporation election), effective as of Date 2.