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FEATURED CONTENT
Thinking About Selling Body Parts as a Side Hustle? Review the Tax Consequences First!
Sometimes my mind is not the safest place to be. I mean face it, a few issues ago I wrote on best practices for doing Al Capone’s tax returns. But how did I even get started thinking about the taxability of a business dealing in black market organs? Well, it started when someone on social media (perhaps looking to supplement the income from their tax practice) asked if the gain on selling a kidney was taxable and, if so, what would be the seller’s basis in the organ? Then there was that time I was having dinner and adult beverages with some tax colleagues in Las Vegas, and we started talking about that old urban legend about waking up in a bathtub full of ice missing a kidney. It was a fun night, and we all woke up with all of our kidneys and other organs in place. Nevertheless, I found myself wondering (and continuing to wonder) about the tax consequences of transacting in human body parts—one’s own or those illegally harvested from others. Turns out, there have been some court cases on the topic which means that the discussion is more than merely theoretical.
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CURRENT EDITION
Worrisome Messages Subtly Delivered Via Recent Tax Developments
Tax professionals are inundated with tax developments from all branches of the government and from all levels of government on a daily basis. Our technical tax knowledge expands weekly. Given the immensity of tax law changes in P.L. 119-21 (July 4, 2025), informally named the One Big Beautiful Bill Act (OBBBA), and the guidance we’ll continue to get over the next few years along with non-OBBBA updates, we might run out of time and bandwidth to step back and ask what additional relevance this guidance, as well as various reports issued by the government every day, mean for the well-being of our tax system. This article unpacks select tax law changes and government documents to offer four subtle messages within them. Generally, the messages don’t bode well for an effective tax and revenue system. The article ends with some suggestions on what can help improve our tax system.
Sirius Solutions and the S Corp or Partnership Choice
The Fifth Circuit Court of Appeals opinion in Sirius Solutions L.L.L.P. v. Commissioner may change our views of entity choice. If the decision holds up, partnerships will be able to effectively make the portion of limited partner income subject to self-employment tax whatever they want, including zero. This contrasts with the IRS position upheld by the Tax Court in Soroban Capital that treated all of the income of limited partners who were active in the business as self-employment income.
Niche Down to Scale Up: How Specialization Drives Visibility and Profitability
For many accountants, narrowing our focus can feel risky. We are trained to serve anyone who needs help and provide stability in any financial situation. Choosing a niche often raises concerns: Will we turn away good clients? Will we limit opportunities or reduce business stability? These are common doubts many of us have faced in our careers.
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