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
Continue Reading “I Declare Nonrecognition!” Why the IRS Says Certain Section 351/ETF Conversions Don’t Work That WayAdam Young
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IRS Issues Proposed Regulations for Qualified Opportunity Zones – What You Need to Know
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On September 10, 2026, the Treasury Department and IRS issued proposed regulations implementing key provisions of the One Big Beautiful Bill Act (OBBBA) related to qualified opportunity zones (QOZs) and…
Continue Reading IRS Issues Proposed Regulations for Qualified Opportunity Zones – What You Need to KnowIRS Proposes New Racial Nondiscrimination Rules for Tax-Exempt Private Schools: What Your School Needs to Know
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On September 4, 2026, the IRS and Treasury Department published proposed regulations (REG-119986-25) that would redefine the nondiscrimination standards every tax-exempt private school must meet under section 501(c)(3). If finalized…
Continue Reading IRS Proposes New Racial Nondiscrimination Rules for Tax-Exempt Private Schools: What Your School Needs to KnowIRS Revenue Officers Will Be Knocking on Doors in Lancaster County This August – Here’s What You Need to Know
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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 KnowTax Court Holds BBA Partnership Petition Filing Deadline Is Not Jurisdictional
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In 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 JurisdictionalThe Growing Business of Sports: A Tax Playbook Review
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Get 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
By Adam Young & Elizabeth Blickley on
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 DeloreanNo Points for Participation: Passive Activity Rules and Loss Limitations
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Classroom 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 LimitationsIRS Targeting Charitable Deductions: Old Dog, Old Tricks
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At 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 TricksRhetoric Aside, Audits of Tax-Exempt Organizations Skyrocketed in FY25
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The 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 FY25