2024-06-24 Supreme Court Upholds the 965 Transition Tax

06/23/24 • -1 min

This week we look at:

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

An audio only version of this week’s broadcast can be downloaded or streamed below:

A PDF with the citations and copy of the slides for this week can be downloaded below:

This week we look at:

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

An audio only version of this week’s broadcast can be downloaded or streamed below:

A PDF with the citations and copy of the slides for this week can be downloaded below:

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

An audio only version of this week’s broadcast can be downloaded or streamed below.

The citations and slides for this week’s broadcast can be downloaded as a PDF form the link below:

This week we look at:

Ninth Circuit rules that statute of limitations for the IRS to sue for recovery of erroneous refund begins when the check clears the Federal Reserve and is approved for payment by the US Treasury
IRS National Taxpayer Advocate announces the IRS will automate FTA abatement of penalties beginning in 2026
Attorneys report some ERC claimants now interesting in filing suit to accelerate their claim processing

An audio version of this week’s braodcast can be streamed or downloaded below.

A PDF with the slides and citations can be downloaded below.