The rise of chatbots and AI assistants has blurred the lines between traditional search engines and conversational AI. Tools like ChatGPT and its latest iteration, GPT-4o, are reshaping how Certified Tax Planners (CTPs) search for tax information. A new and fragmented multi-search universe has emerged that offers CTPs a broader array of tools tailored to their specific needs for due diligence. Let's take a look at 10 new AI search tools that can maximize your efficiency today!

Just How “Hot” Should IRC Section 751 Be?
Tax rules are generally designed with a purpose in mind. Most rules serve to define the tax base and tax rates. Many others serve a behavioral purpose to encourage or discourage certain activities. The focus of this article stems from tax rules that are a combination of favoring certain activity such as generation of capital gains, and a limitation on such gains for certain taxpayers, such as the so-called “hot assets” rule for partners under IRC Section 751, Unrealized Receivables and Inventory Items. While Section 751 has been in the tax law for decades, a new application of it was raised by both the IRS and California FTB. This article summarizes Rawat, TC Memo 2023-14, rev’d, No. 23-1142 (DC Cir., 2024), and FTB Legal Ruling 2022-02, and offers observations on their relevance to tax research and practice.