Loopholes

TAX COURT ROUNDUP – MARCH 2024

February was Discovery Month at Tax Court. The high-deficiency, high-profile conservation easement cases coming from IRS crackdown put a premium on the old continuing legal education staple "win your case at discovery." But it doesn't go so well for shotgun demands, nor for broad-spectrum claims of privilege. Of course, more was resolved than just discovery disputes, but I'll get to those.

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Think Outside the Tax Box provides tax reduction strategies along with practical implementation advice in order to reduce your clients’ federal tax bill with ease.

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CURRENT EDITION

Charitable Impacts of the One Big Beautiful Bill Act

Thomas Gorczynski, EA USTCP CTP

For charitable-minded taxpayers, several provisions in the One Big Beautiful Bill Act (OB3 Act) will impact the tax reduction associated with their charitable giving starting next year in 2026. In one case, the change increases the deductible amount, but all other changes surprisingly reduce the value of charitable contribution deductions. This article will review how the OB3 Act changed the charitable contribution deduction landscape and strategies for tax year 2025 and beyond to maximize the tax reduction value from charitable contributions.

A Tax Tailored for Twenty-Six: OBBBA’s Impact on College Endowments

Peter J Reilly CPA

Chapter 4 of the One Big Beautiful Bill (OBBBA) is titled “Investing In American Families, Communities.” Subchapter B of Chapter 4 is “Permanent investments in students and reforms to tax-exempt institutions.” That is where you will find “Modification of excise tax on investment income of certain private colleges and universities.” What is really amusing about this rewrite of IRC Section 4968 “Excise tax based on investment income of private colleges and universities” is that it applies to such a small number of institutions that you can identify them with a decent degree of certainty from publicly available information. The tax does not apply to state universities.

10 Key Things Tax Professionals Should Know About State and Local Business Incentives

Garret Wasny, MA, CMC, CITP/FITP

State and local business tax incentives are powerful tools that can significantly reduce a company’s tax burden and influence business decisions. Every U.S. state offers some form of incentive to attract or retain businesses, from tax credits and exemptions to cash grants and property tax abatements. For experienced tax professionals, understanding these incentives is crucial for effective tax planning and helping clients maximize savings. Below are ten key things to know about state and local business incentives, along with real-world examples and actionable insights. We’ll also wrap up with essential dos and don’ts when advising clients on these programs.