On September 28, 2026, Treasury and the IRS issued Revenue Ruling 2026-20 and Notice 2026-62. Together they address Section 351/ETF conversions, ETFs’ use of in-kind redemptions to avoid income and non-qualifying income recognition, and investment funds’ strained reading of technical rules to generate taxpayer-favorable capital gains and ordinary losses.…
Continue Reading “I Declare Nonrecognition!” Why the IRS Says Certain Section 351/ETF Conversions Don’t Work That WayIRS Issues Proposed Regulations for Qualified Opportunity Zones – What You Need to Know
On September 10, 2026, the Treasury Department and IRS issued proposed regulations implementing key provisions…
Continue Reading IRS Issues Proposed Regulations for Qualified Opportunity Zones – What You Need to KnowNew Trial Cities, Broader Access, and a Pilot of a Smarter Calendar
On September 8…
Continue Reading Your U.S. Tax Court Case Just Got Closer to HomeIRS Proposes New Racial Nondiscrimination Rules for Tax-Exempt Private Schools: What Your School Needs to Know
On September 4, 2026, the IRS and Treasury Department published proposed regulations (REG-119986-25) that would…
Continue Reading IRS Proposes New Racial Nondiscrimination Rules for Tax-Exempt Private Schools: What Your School Needs to KnowSubscribe to Tax Controversy & Financial Crimes Report
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IRS Revenue Officers Will Be Knocking on Doors in Lancaster County This August – Here’s What You Need to Know
If you own a business or reside in Lancaster County, pay close attention: the IRS confirmed in a July 21, 2026 letter that 20 revenue officers will be conducting face-to-face…
Continue Reading IRS Revenue Officers Will Be Knocking on Doors in Lancaster County This August – Here’s What You Need to KnowIn Big Apple Tompkins Realty LLC v. Commissioner, the Tax Court addressed a question of first impression: whether I.R.C. § 6234(a)’s 90-day petition filing deadline for partnerships subject to…
Continue Reading Tax Court Holds BBA Partnership Petition Filing Deadline Is Not JurisdictionalGet your popcorn ready because there is nothing more exciting than the intersection of sports and tax! As a former Division II athlete, the current state of college sports and…
Continue Reading The Growing Business of Sports: A Tax Playbook ReviewBack to the Future: Tax Edition — Correcting SSN/TIN Issues Before the IRS Repossesses the Delorean
Every January, businesses race to issue Forms W-2, 1099, and 1099-NEC, but a small typo in a Social Security Number (SSN) or Taxpayer Identification Number (TIN) can turn into a…
Continue Reading Back to the Future: Tax Edition — Correcting SSN/TIN Issues Before the IRS Repossesses the DeloreanClassroom participation points may boost a child’s grade in history class, but merely raising your hand won’t get you far with the IRS. The passive activity loss rules under I.R.C.
Continue Reading No Points for Participation: Passive Activity Rules and Loss LimitationsOn July 1, 2026 the IRS unveiled a new portal for Kwong related refund claims. Taxpayers who want file Forms 843 claiming a refund for interest or penalties that accrued…
Continue Reading IRS Launches Online Portal for Kwong Refund ClaimsAt the NYU Tax Controversy Forum last week, (former?) Acting IRS Chief Counsel Ken Kies commented on the IRS conservation easement settlement initiative and noted that the IRS…
Continue Reading IRS Targeting Charitable Deductions: Old Dog, Old TricksThe current administration’s focus on tax-exempt organizations is no secret. But the recent release of the IRS Databook for FY25 shows that the IRS is following through on the…
Continue Reading Rhetoric Aside, Audits of Tax-Exempt Organizations Skyrocketed in FY25In a June 9 opinion, the Tax Court held that a married couple were not engaged in horse breeding and training activities for profit and sustained the IRS’s disallowance…
Continue Reading Horse Breeding and Training Expense Deductions? Tax Court Says NeighAbout this Blog
Published by attorneys in the White-Collar Criminal Defense & Regulatory Compliance and Taxation & Wealth Planning practices of national law firm Fox Rothschild LLP, Tax Controversy and Financial Crimes Report reports on the latest developments in all aspects of tax controversy and financial crimes.