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Recent Hobby Loss Developments
Section 183, which limits or entirely eliminates deductions attributable to activities not entered into for profit, may be coming in for more attention from an invigorated IRS. Section 183 is commonly referred to, not without reason, as the hobby loss rule. Based on my extensive study of the case law, I believe that practitioners widely misunderstand 183. I have noted cases where taxpayers had not gotten a heads up from their adviser. More commonly there is a misunderstanding of 183(d), a presumption in favor of taxpayers that is rarely relevant at all, but which the agency can never use against them. Most important is the failure to appreciate that it is the objective of making a profit not the expectation that is necessary. With that in mind here are the most recent developments...
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CURRENT EDITION
Trump Accounts Are Live. Are They Spectacular?
Trump Accounts (or § 530A accounts) went live via app on July 4, 2026. According to the Treasury Department, over six million accounts have been opened. As of Monday, July 6, 2026, parents and guardians of account beneficiaries could use the app to view their children’s accounts, fund the accounts, and access balances and financial education information. The Treasury Department designated BNY Mellon “as a financial agent of the U.S. government to support implementation of the new Trump Accounts program.” BNY, in partnership with Treasury, will manage the accounts and help to develop the app taxpayers can use to manage their accounts. Robinhood Securities, LLC is acting as the initial trustee and brokerage for the accounts.
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.
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