CURRENT EDITION

Will AMT Make a Comeback After OBBBA?
Following Betteridge’s Law of Headlines, the answer to the question posed in the headline is, “no.” Actually — because we’re talking about taxes here — we can say the answer is never so definitive, so let’s change it to “probably not.” But it's more complicated than it may seem.
READ MORERevolutionizing Client Engagement: The Shift from EPTI to PAVER in Tax Reporting with Generative AI
Are you seeking innovative strategies to elevate your client reporting processes? Wondering how to transition from traditional methods to more engaging and personalized interactions? The emergence of generative AI has instigated a profound transformation in the domain of client communication for tax planners, shifting from the conventional Email, PDF, Telephone, In-person (EPTI) reporting techniques to a more advanced PAVER framework. Read on to find out more!
Read MoreHobby Loss Developments in 2023
The laws of tax planning that I developed over my writing career that will be expounded in the upcoming Reilly’s Laws of Tax Planning, published by Think Outside the Tax Box, lean a little on the conservative side, as tax planners use the term – conservative versus aggressive, not conservative versus liberal. This results, in large part, from their primary source being court decisions. The 18th law stands out from the others in this regard. “Honest objective trumps realistic expectation” encourages practitioners to be somewhat more aggressive in claiming losses from activities that seem a little dubious . I still hold that view, even though there have been no encouraging developments in 2023. Here is a roundup on the action last year through December 2, 2023.
Read MoreCrypto Gains and Tax Court Games: Exploring the “Unclean Hands” Defense
Baseball, apple pie, and finding creative ways to pay fewer taxes, is there anything more American? Judge Learned Hand famously said in 1934, “Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to increase one’s taxes.” Since the inception of the Federal Income Tax, taxpayers have looked for increasingly creative ways to avoid it. This exploration is no different: A taxpayer attempts to wash his hands of his tax liability all together.
Read MoreTAX 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.
Read MoreMitigating Risks: A Roadmap for Withdrawing Employee Retention Credits or Filing Income Tax Returns for Clients Who Have
Just in – the IRS dropped a hot alert about the Employee Retention Credit (ERC), and it's time to pay attention . With the March 22, 2024, deadline creeping up for the ERC Voluntary Disclosure Program, it's crucial for those who mistakenly filed a claim to take action. This program lets businesses repay just 80% of the claimed amount, so it's a chance to make things right. If your clients filed a claim that's still in the pipeline, it's time for a double-check. Review the guidelines ASAP and withdraw the claim if it doesn't pass muster.
Read MoreSoapbox Ethics: Circular 230 And the Unauthorized Practice of Law
The beneficial ownership reporting requirement established by the Corporate Transparency Act has created a fair amount of chaos concerning whether providing reporting services to clients is the unauthorized practice of law (UPL). While some state bar associations have come down on one side or the other as to whether certain types of reporting are UPL, the Treasury offers no clear guidance. What the IRS has made clear recently is that Circular 230 ethical obligations extend to matters beyond what the Loving case determined was “practice before the IRS.”
Read MoreHow Tax Professionals Can Navigate Complex Financial and HR Conversations Using AI: The ChatGPT C.A.R.E. Method
In the intricate world of accounting, tax professionals are often perceived as navigators traversing through the seas of numbers and financial statements. A lesser-discussed aspect of their role is the management of complex and emotionally charged conversations. Tax accountants frequently find themselves at the center of discussions that are not just about figures on a spreadsheet but deeply intertwined with the personal and business well-being of their clients. From addressing audit discrepancies to handling sensitive tax liabilities, these scenarios demand more than just technical know-how; they require a blend of empathy, clear communication, and emotional intelligence.
Read MoreThe Latest on Proposals for a Wealth Tax
Should the rich pay more taxes? Are they dodging their equitable responsibility? Or do wealth taxes discourage people from the American dream of trying to get rich? Taxes are what the other guy in America should pay and the rich, with headline exemptions like Warren Buffet and Bill Gates , usually join the chorus of taxpayers who say they don’t want to pay more taxes no matter how much they’re worth. Call the concept one of a fair share or just simply unfair, a national wealth tax continues to ignite debate and legislation. What’s the latest?
Read MoreNOT A Subscriber YET?
SUBSCRIBE TO GET ALL OF OUR
GREAT ARTICLES AND RESOURCES!
CURRENT EDITION

Will AMT Make a Comeback After OBBBA?
Following Betteridge’s Law of Headlines, the answer to the question posed in the headline is, “no.” Actually — because we’re talking about taxes here — we can say the answer is never so definitive, so let’s change it to “probably not.” But it’s more complicated than it may seem.

Why Citizenship, Residency, and Domicile Matter
If you spend any time in the world of cross-border taxes, you start to notice a pattern: the hardest problems usually begin with a deceptively simple question—who gets to tax you? And the answer is rarely as simple as “the country where I live.” That’s because tax systems don’t rely on just one concept to decide who belongs in their net. They use citizenship, residency, and domicile. These terms sound similar, and people often use them interchangeably in casual conversation, but in tax law they mean very different things. For globally mobile individuals, understanding the difference matters. You can be a U.S. citizen, a tax resident of another country, and still have your long-term home base tied to a different jurisdiction altogether. Each label can trigger different tax consequences, different filing obligations, and different planning opportunities.

Sophisticated EMR Software Meets Old-School Skimming: Lessons From The Aryanpure Case
The simplest way to reduce your taxable income from an S corporation is to take some of the gross receipts directly into your personal account without running them through the corporate books. Don’t mention this to your tax preparer and make sure they don’t find out. If you get caught by the IRS, though, hire an expert to explain why it is your preparer’s fault. This plan did not work all that well for a couple, both physicians, who were running two medical family medical clinics through an S Corporation called MedExpress. They ended up being liable for the fraud penalty which has the collateral effect of extending the statute of limitations indefinitely. At 75% the fraud penalty is as bad as it can get without losing your liberty.








