The United States Court of Appeals for the Fifth Circuit has delivered a significant decision regarding self-employment (SE) tax liability for limited partners, overturning the Tax Court’s reliance on the "functional analysis" test established in Soroban Capital Partners LP v. Commissioner. In Sirius Solutions, L.L.L.P. v. Commissioner, No. 24-60240 (5th Cir. 2026), the Fifth Circuit rejected the IRS’s position that the Section 1402(a)(13) exclusion applies only to "passive investors." Instead, the Court held that the statutory term "limited partner" must be interpreted based on its ordinary meaning at the time of enactment: a partner in a limited partnership who possesses limited liability.

This article details the factual background, the arguments presented, and the technical statutory analysis employed by the Fifth Circuit in this pivotal ruling.

The United States Tax Court, in its recent memorandum opinion Whistleblower 11099-13W v. Commissioner, T.C. Memo. 2026-5, addressed a pivotal question for tax professionals regarding the definition of "collected proceeds" under Internal Revenue Code (I.R.C.) § 7623(b). The case centers on whether a whistleblower is entitled to an award when a taxpayer, allegedly prompted by an IRS investigation, voluntarily changes its accounting method and self-reports additional tax on original returns.

As tax professionals, it is critical to stay updated on the specific exclusions provided to members of the U.S. armed forces. A recent development from the Internal Revenue Service has clarified the treatment of one-time supplemental payments, reinforcing the broad protections offered under the Internal Revenue Code (IRC).

IRS News Release IR-2026-09: The "Warrior Dividend"

On January 16, 2026, the Department of the Treasury and the IRS issued News Release IR-2026-09, confirming that supplemental basic allowance for housing (BAH) payments made to members of the uniformed services in December 2025 are not taxable.

Internal Revenue Bulletin publication of Revenue Procedure 2026-8 marks a significant shift in the administration of group tax-exempt status under § 501(c). This procedure "modifies and supersedes Rev. Proc. 80-27" and "sets forth updated procedures to obtain recognition of exemption from federal income tax on a group basis". For practitioners, this guidance is the first comprehensive update in over four decades, designed to align the group exemption process with modern electronic filing requirements and more stringent oversight standards.

The Internal Revenue Service (IRS) recently issued Notice 2026-13, which provides updated safe harbor explanations for plan administrators to satisfy the requirements of Internal Revenue Code (IRC) Section 402(f). This notice is a response to significant legislative modifications introduced by the SECURE 2.0 Act of 2022 and recommendations from the U.S. Government Accountability Office (GAO) regarding participant comprehension of distribution options. For tax professionals, understanding these revisions is essential to ensuring plan compliance and providing accurate guidance on the taxability of distributions from exempt employees’ trusts.

The enactment of Public Law 119-21, 139 Stat. 72, known as the One, Big, Beautiful Bill Act (OBBBA), on July 4, 2025, represents a significant shift in the federal tax treatment of capital expenditures. For tax practitioners, the primary vehicle for understanding the administrative implementation of these changes is Notice 2026-11, which provides interim guidance on the additional first-year depreciation deduction under Internal Revenue Code Section 168(k). This analysis examines the statutory modifications, the IRS’s technical substitutions for existing regulations, and the specific treatment of newly eligible asset classes through the lens of strict statutory construction.

The determination of whether an unsatisfied tax obligation constitutes a "deficiency" under IRC § 6211 or an amount "shown on the return" under IRC § 6201 dictates the procedural rights of a taxpayer. In Walker v. Commissioner, T.C. Memo. 2026-4, the United States Tax Court addressed a critical procedural question regarding the Premium Tax Credit (PTC): Must the IRS issue a Notice of Deficiency before assessing excess Advance Premium Tax Credit (APTC) repayments when the reconciliation form is submitted after the original return? The Court held that such liabilities constitute deficiencies, requiring the IRS to follow deficiency procedures rather than summary assessment.

The Internal Revenue Service has issued News Release IR-2026-02, formally announcing the commencement of the 2026 filing season. For tax practitioners, this season presents significant compliance changes resulting from the "One, Big, Beautiful Bill." Key developments include the introduction of Schedule 1-A to handle new exclusions for tips and overtime, the deployment of Form 1099-DA for digital assets, and a mandatory shift toward electronic funds transfer for refunds.

The Department of the Treasury and the Internal Revenue Service (IRS) have issued proposed regulations (REG-112829-25) addressing backup withholding obligations for Third Party Settlement Organizations (TPSOs). These proposals are designed to harmonize the backup withholding regulations under Internal Revenue Code (IRC) section 3406 with the recent statutory amendments to IRC section 6050W enacted by the "One, Big, Beautiful Bill Act" (OBBBA).

For tax professionals advising TPSOs or participating payees, these proposed regulations represent a significant technical shift from the existing regulatory framework. Specifically, they modify the determination of "reportable payments" subject to backup withholding by incorporating the de minimis thresholds found in section 6050W(e).

In a decision solidifying the judicial consensus regarding civil penalties under the Bank Secrecy Act (BSA), the United States Court of Appeals for the Second Circuit recently affirmed a summary judgment ruling in United States v. Reyes. The court held that the statutory term "willfully" encompasses reckless conduct for purposes of imposing enhanced civil penalties for failing to file a Report of Foreign Bank and Financial Accounts (FBAR). Furthermore, the court confirmed that the six percent late payment penalty assessed by the Treasury Department is mandatory, leaving district courts with no discretion to reduce it.

For tax professionals representing clients with significant noncash charitable contributions, the statutory and regulatory substantiation hurdles remain high. A recent decision by the United States Tax Court, Gibson v. Commissioner, T.C. Summary Opinion 2026-1, serves as a stark reminder of the consequences of failing to strictly comply with Internal Revenue Code (I.R.C.) section 170(f)(11) and the associated Treasury Regulations. Although summary opinions are not binding precedent, the Gibson case offers a textbook illustration of how the Court applies the tiered substantiation requirements to high-value property donations.

The United States Tax Court recently issued a Memorandum Opinion in Milk Saving Starving Children Foundation v. Commissioner, T.C. Memo. 2026-1, which serves as a stark reminder regarding the operational test under Internal Revenue Code (I.R.C.) section 501(c)(3). The Court granted the Commissioner’s Motion for Summary Judgment, sustaining the revocation of the petitioner’s tax-exempt status due to its failure to operate exclusively for exempt purposes. This article details the factual background, the legal framework applied by Special Trial Judge Leyden, and the specific operational failures that led to the adverse determination.

The Department of the Treasury and the Internal Revenue Service (IRS) have issued Notice of Proposed Rulemaking REG-113515-25, providing guidance on the newly enacted deduction for Qualified Passenger Vehicle Loan Interest (QPVLI). These proposed regulations interpret amendments made to the Internal Revenue Code (Code) by the "One, Big, Beautiful Bill Act" (OBBBA), Public Law 119-21.

In Barney v. Commissioner, T.C. Memo. 2025-133, the United States Tax Court addressed complex issues surrounding the conversion of for-profit entities into nonprofit organizations via a bargain sale. The case serves as a critical study for tax professionals regarding the valuation of distressed assets, the substantiation requirements for charitable contributions under Internal Revenue Code section 170, and the calculation of the amount realized under section 1001 when consideration takes the form of promissory notes.

In the recent Tax Court Memorandum decision Estate of Spenlinhauer v. Commissioner, T.C. Memo. 2025-134, the Court addressed a complex mix of procedural failures, valuation disputes, and phantom assets. For tax professionals, this case serves as a stark reminder of the cascading consequences of failing to timely file Form 706, the strict substantiation requirements for Section 2053 deductions, and the piercing nature of transferee liability under Section 6901.

The Internal Revenue Service has issued its annual guidance regarding the procedures for issuing letter rulings, determination letters, and technical advice. For the 2026 cycle, practitioners must familiarize themselves with Revenue Procedure 2026-1, Revenue Procedure 2026-2, Revenue Procedure 2026-3, Revenue Procedure 2026-4, and Revenue Procedure 2026-5. These documents collectively establish the administrative framework for tax administration, delineating the jurisdiction of Associate Chief Counsel offices, the rights of taxpayers during examination and appeals, and the specific areas where the Service will decline to issue private guidance. The following analysis details the legal basis for these procedures and highlights the significant changes affecting tax practice for the upcoming year.

The Internal Revenue Service has issued Notice 2026-10, establishing the optional standard mileage rates for computing the deductible costs of operating an automobile for business, charitable, medical, or moving expense purposes effective January 1, 2026. This guidance also updates the basis reduction amounts for depreciation and sets the maximum standard automobile cost for fixed and variable rate (FAVR) plans.

On December 23, 2025, the Internal Revenue Service released updated guidance in Fact Sheet FS-2025-10, titled "Updates to Questions and Answers about the Premium Tax Credit." This issuance supersedes previous guidance and incorporates critical legislative changes enacted under P.L. 119-21, specifically regarding the expiration of temporary relief measures codified in Internal Revenue Code (IRC) Section 36B. For tax professionals, the most immediate and material technical updates concern the sunsetting of repayment limitations for excess Advance Premium Tax Credits (APTC) and the adjustment of applicable affordability percentages for tax years beginning after December 31, 2025.

The Internal Revenue Service recently released Fact Sheet 2025-09 (FS-2025-09), providing updated guidance on the limitation on business interest expense deductions under Internal Revenue Code Section 163(j). This guidance incorporates significant statutory amendments arising from the legislation referred to as the "One, Big, Beautiful Bill" (P.L. 119-21). For tax professionals, these updates necessitate a careful review of adjusted taxable income (ATI) computations, the definition of motor vehicles for floor plan financing, and the interaction between interest limitations and capitalization rules.

This article examines the December 2025 revised questions within the Fact Sheet, correlating the IRS’s administrative positions with the underlying statutory text of Section 163(j). Note that while the prompt requests conclusions from a "court" or "judge," the provided source material consists of administrative guidance and statutory code; therefore, the analysis focuses on the conclusions and determinations issued by the IRS and Congress.

The following are detailed descriptions of the top 10 tax crime cases of 2025 as identified by the IRS Criminal Investigation (IRS-CI) Division. These cases involve a range of financial crimes including pandemic relief fraud, public corruption, cybercrime, and tax evasion.