Client Alert
Strict Substantiation: Why Being Right Without Proof Can Cost You Your Charitable Deduction
Reilly’s Sixteenth Law of Tax Planning – Being right without substantiation can be as bad as being wrong – is particularly apt when it comes to charitable contributions. The case law makes it clear that there is not much wiggle room in rules relating to substantiation and reporting of charitable contributions. We’ll dig into the rules here.
Read More
A Court Just Bought Your Clients More Time on Clean Energy Tax Credits Here’s How to Use It
A federal district court just struck down an IRS rule that had been closing the door on a pretty compelling tax savings opportunity available to your clients today, the Section 48E Clean Electricity Investment Tax Credit. The ruling, handed down on June 6, 2026, reinstated a key pathway that allows investors to lock in credit eligibility for large-scale wind and solar projects a pathway the IRS had tried to eliminate just last year. The window is not wide open. July 4, 2026 is still the critical deadline, and the government will almost certainly appeal. But for advisors who act quickly, this ruling creates a genuine, time-sensitive planning opportunity. Here is what you need to understand, and what you should be doing right now.
Read More
NOT A MEMBER YET?
SUBSCRIBE TO GET ALL OF OUR
GREAT ARTICLES AND RESOURCES!
CURRENT EDITION
2026 Changes to Form 2441 and Dependent Care Benefits
The credit for dependent-care expenses (such as daycare costs) has long been stuck at 20% for “average” taxpayers. It finally gets a permanent boost in 2026 (for returns filed in 2027). Also, the amount of money a taxpayer can put into a dependent care assistance program is increasing by $2,500 for 2026. This change presents a chance for taxpayers and tax pros to reevaluate which is better – claiming the credit or using a flex plan.
Turning Intellectual Property into Interest Deduction Capacity: Use of an IP Holdco After the OBBBA
Many taxpayers have lived with a frustrating mismatch since the Section 163(j) limitation tightened after 2021 – the business may generate plenty of cash, yet its interest deductions are limited because adjusted taxable income (“ATI”) is too low, e.g., due to capex. The 2025 restoration of depreciation and amortization addbacks makes ATI planning relevant again, especially for groups that own valuable intangible property (“IP”), and the choice of legal entity to house group IP may have very different tax consequences as discussed in this article.
Do You Know U.S. Tax History?
In recognition of the 250th anniversary of the adoption of the Declaration of Independence on July 4, 1776, let’s review 250 years of tax history. Our nation’s tax systems have evolved over two and a half centuries as ways of doing business and living have changed. Also, expectations of services the public wants and needs from the government have grown, resulting in tax changes to generate increasing amounts of tax revenue. Along the way, lawmakers have considered principles of simplification, equity, fairness, economic growth and effective tax administration that have shaped our tax laws. This article offers questions and answers to cover a range of interesting aspects of our federal tax history.
