Taxation General Discussion - Recent Threads

Experts Say Holistic Tax Strategy Needed for Data Center Investments

Neil Vicente — Mon, 18 May 2026 12:39:55 GMT

The sheer scale and speed of the current AI-driven data center boom require a fundamental shift in how tax is viewed within an organization, according to the experts. The development of multi-gigawatt campuses involves billions in capital, a multitude of stakeholders, and an array of innovative financial structures. This environment creates considerable headwinds, making early and strategic tax planning essential to ensuring capacity can be delivered on time and on budget. The webcast explained.

“We’re seeing complexity and supply chain constraints, certainly in power constraints and sort of innovative approaches to meeting the power demand,” said Matt Cardamone, principal of Capital Projects & Infrastructure at the firm. He explained that this complexity is amplified by the scale of capital expenditures, the number of stakeholders, and the innovative financial structures being used.

To dig deeper, visit the original article on the Thomson Reuters blog.

GOP Lawmakers, Trump Push Proposals to Suspend Federal Gas Tax

Neil Vicente — Mon, 18 May 2026 12:24:47 GMT

On May 11, Senator Josh Hawley (R-MO) introduced the Gas Tax Suspension Act, S. 4485, to reduce the tax rate on non-aviation gasoline and diesel fuel to zero. The bill would do so by amending IRC § 4081(a)(2)(A). The move would pause the 18.4-cents-per-gallon tax on gasoline and the 24.4-cents-per-gallon tax on diesel fuel.

Hawley’s bill would suspend the federal gas tax for at least 90 days. It also would give the president authority to extend the suspension for an additional 90 days if “economic conditions” warrant it.

Hawley cites the national average prices for regular gasoline and diesel fuel — over $4.50 per gallon and nearly $5.70 per gallon, respectively — as the reason for his proposal.

To dig deeper, visit the original article on the Thomson Reuters blog.

Senate Bill Takes Aim at Corporate Transparency Act

Nageshwaran Gopal — Mon, 11 May 2026 16:33:22 GMT

Senators Target CTA

The Senate bill, S. 4419, headed up by Senators Mike Lee (R-UT) and John Kennedy (R-LA), would narrow beneficial ownership reporting requirements. These requirements were put in place after Congress enacted the Corporate Transparency Act (CTA) in an effort to combat money laundering, trafficking, and other illicit activities.

The CTA requires specified entities or “reporting companies” to submit reports indicating their beneficial owners to Treasury’s Financial Crimes Enforcement Network (FinCEN). Reporting has largely been on pause, however, due to pending litigation and Trump administration actions.

To dig deeper, visit the original article on the Thomson Reuters blog.

Why choose ONESOURCE for your direct tax software?

Nageshwaran Gopal — Mon, 11 May 2026 16:20:16 GMT

Highlights

ONESOURCE automates tax compliance across federal, state, local, and international jurisdictions in one platform.
Organizations achieved 148% ROI with 50% reduction in tax preparation time and avoided compliance costs.
Cloud-native architecture ensures automatic updates for evolving regulations including BEPS 2.0 Pillar Two compliance.

To dig deeper, visit the original article on the Thomson Reuters blog.

Temporary Dyed Fuel Refund Regs Issued, IRS Seeks Comments

Neil Vicente — Mon, 04 May 2026 12:46:33 GMT

Background

The federal excise tax under IRC § 4081 is imposed on the removal of taxable fuel from a terminal. In some industry situations, previously taxed clear fuel is returned to the bulk transfer/terminal system and then removed a second time. While a refund mechanism has long existed for fuel that was taxed twice for taxable uses, there was previously no method for a taxpayer to recover the first tax if the fuel was later dyed and removed for a nontaxable purpose.

To address this, the One Big Beautiful Bill Act (OBBB) added IRC § 6435. This provision establishes a statutory refund mechanism for fuel removed on or after December 31, 2025. After the law’s passage, the IRS issued Ann. 2026-1, which requested that taxpayers hold any claims under the new law until formal guidance could be developed and released. This new set of regs provides that anticipated guidance.

To dig deeper, visit the original article on the Thomson Reuters blog.

Dems Oppose Treasury on Partnership Rules, Refundable Credits

Neil Vicente — Mon, 04 May 2026 12:42:28 GMT

Senators Oppose Removing Partnership Basis Adjustment Reporting

Senator Elizabeth Warren (D-MA) and five Senate colleagues urged Secretary Bessent and Assistant Secretary for Tax Policy Kenneth Kies to withdraw a March 6, 2026, notice of proposed rulemaking (NPRM) that would eliminate a reporting requirement for related-party partnership basis adjustment transactions.

In their letter, the senators wrote that the NPRM “will remove a simple reporting requirement, which will neutralize one of the few remaining tools available to the IRS to spot abusive partnership transactions.”

Under longstanding IRS rules, partners and partnerships may (and in certain cases must) adjust the tax basis of property following certain transactions. Some businesses and high-net-worth individuals, the senators contended, have used complex partnership structures to apply these basis-shifting rules and create “significant tax savings without real costs or changes in economic position.”

To dig deeper, visit the original article on the Thomson Reuters blog.

Navigating the Tax Consequences of Tariff Refunds

Nageshwaran Gopal — Mon, 27 Apr 2026 13:25:54 GMT

A recent U.S. Supreme Court ruling invalidating International Emergency Economic Powers Act (IEEPA) tariffs has opened the door for companies to claim billions of dollars in refunds, but the process will be complex. A refund system went live on April 20, and as companies prepare to file claims, PwC’s Chris Desmond unpacked potential tax and transfer pricing consequences.

While a large refund is welcome news for any company’s finance department, it’s also a tax event, Desmond explained. That’s because a refund results in “a reduction in the cost of goods sold,” which in turn increases a company’s taxable income. Companies need to have a plan to account for this, Desmond detailed in a recent PwC podcast and a conversation with Checkpoint.

To dig deeper, visit the original article on the Thomson Reuters blog.

Bill Seeks Earned Income Tax Credit Boost per Child for Working Parents

Nageshwaran Gopal — Mon, 27 Apr 2026 12:15:14 GMT

Expanding the Earned Income Tax Credit for Young Children

The Working Parents Tax Relief Act of 2026, H.R. 8305, would amend IRC § 32(c) to increase the EITC for eligible filers with qualifying children under age 4. The bill’s primary provision would give qualifying filers up to an additional $5,500 per child under age 4, for a maximum of three children.

Under the bill, a filer with one qualifying child under age 4 would see the credit percentage increased by 42.24 percentage points. Filers with two or more qualifying children would see the credit percentage increase by 30.07 percentage points for each of their youngest three qualifying children under age 4. The phaseout percentage would also increase by five percentage points for each such qualifying child, up to three.

To dig deeper, visit the original article on the Thomson Reuters blog.

What is Schedule K-1?

Neil Vicente — Mon, 13 Apr 2026 12:34:06 GMT

Schedule K-1s, which are tax forms used to report a partner’s or shareholder’s income, losses, capital gain, dividends, etc., to the IRS, are sent to more than 40 million U.S. taxpayers each year.

There are several different types of K-1 forms, which we will discuss later, but the K-1 is designed to make it easier to measure the contributions of a shareholder toward the overall performance of a business.

K-1s are sometimes confused with Form 1099s, which are tax information documents for individuals who are not employees, like sole proprietors and freelancers. K-1s, however, are quite different and can come with some complexities for tax and accounting firms.

To dig deeper, visit the original article on the Thomson Reuters blog.

DOJ Criminal Tax Section Moves Again

Neil Vicente — Mon, 13 Apr 2026 12:31:01 GMT

The new task force is chaired by Vice President Vance, and includes representatives from Treasury, the Department of Justice, and several other agencies. Its directive is to develop “a comprehensive national strategy to stop fraud, waste, and abuse within Federal benefit programs, including programs administered jointly with State, local, tribal, and territorial partners.”

The focus of the executive order is on misuse of taxpayer funds. Likewise, Blanche’s memo announcing the Tax Section move emphasizes that the “core mission” of the new National Fraud Enforcement Division is “to zealously investigate and prosecute those who steal or fraudulently misuse taxpayer dollars.” The memo also calls for realignment of other “criminal prosecutorial resources” into the National Fraud Enforcement Division.

However, some are worried that the change means a narrowed mission for the Criminal Division’s Tax Section. “Moving DOJ’s Tax Section to the National Fraud Enforcement Division sends the unfortunate signal that the acting Attorney General is interested in limiting the scope of DOJ’s tax enforcement to those who steal or fraudulently misuse taxpayer dollars” said Dave Hubbert, senior fellow at NYU’s Tax Law Center and the former head of the DOJ Tax Division.

To dig deeper, visit the original article on the Thomson Reuters blog.

Multistate Tax Trends: A Q&A with SALT Expert Niki Ford on Nexus, Marketplaces, AI, and the Future

Neil Vicente — Mon, 13 Apr 2026 12:27:16 GMT

Multistate tax practice is always evolving. The Catalyst state team stays on top of trends, frequently consulting with SALT practitioners on the front lines and incorporating their insights, along with our in-depth analysis, into Checkpoint Catalyst topics that integrate into CoCounsel Tax. This new Multistate Tax Trends Q&A series for Checkpoint News delivers quick, actionable insights from some of these practitioners.

The first installment features Niki Ford, a partner with Baker McKenzie who represents multinational and domestic corporations, LLCs, partnerships, and individuals in income tax and sales tax controversies and planning. As a former Catalyst editor, Niki enhanced many Catalyst topics.

Here Niki and Catalyst’s Rebecca Newton-Clarke discuss emerging issues in SALT practice, including nexus, P.L. 86-272, marketplaces, deference, and more.

To dig deeper, visit the original article on the Thomson Reuters blog.

Court Strikes Down Proposed Settlement in Johnson Amendment Case

Neil Vicente — Mon, 06 Apr 2026 12:30:51 GMT

National Religious Broadcasters, Intercessors for America, and two churches filed suit against the IRS in the U.S. District Court for the Eastern District of Texas, arguing that the Johnson Amendment violates their 1st Amendment rights to freedom of speech and religion, among other claims. The lawsuit was filed in 2024, while former President Biden was in office.

The IRS initially sought to dismiss the suit, countering that § 501(c)(3) does not restrict a constitutionally protected activity; rather it sets eligibility requirements for an organization to receive a government subsidy via the tax system. The IRS noted in a December 2024 brief that “[p]laintiffs remain free to intervene in political campaigns if they so choose even if they cannot receive tax-exempt status and tax-deductible contributions under Section 501(c)(3).”

To dig deeper, visit the original article on the Thomson Reuters blog.

First Circuit Rejects ACA Section 1557 Challenge to Plan’s Weight-Loss Drug Exclusion

Neil Vicente — Mon, 06 Apr 2026 12:16:33 GMT

The First Circuit has affirmed the dismissal of a lawsuit challenging a health plan’s exclusion of weight-loss drugs, holding that a participant did not plausibly allege she had a disability simply by stating she had been diagnosed with obesity and prescribed medication to treat it. The participant filed a proposed class action lawsuit against a health insurer, alleging disability discrimination under Affordable Care Act (ACA) Section 1557. The participant asserted that her obesity was a disability and that the insurer discriminated against her by designing and administering health plans that categorically excluded coverage for prescription weight-loss medications. (Section 1557 prohibits discrimination on grounds specified in several federal laws, including Section 504 of the Rehabilitation Act, which bars discrimination based on disability.) The district court dismissed the case, ruling that the participant had not plausibly shown that she was disabled merely as a function of her body mass index, nor that the insurer had ever regarded her as disabled.

To dig deeper, visit the original article on the Thomson Reuters blog.

Members of Congress Tell Court IRS Unlawfully Gave ICE Bulk Addresses

Neil Vicente — Mon, 06 Apr 2026 12:14:21 GMT

Revelations From Disclosure Declaration

The legal challenge concerns a new IRS address-sharing policy and a related Memorandum of Understanding with ICE. After the IRS disclosed confidential address information for approximately 47,300 taxpayers to Immigration and Customs Enforcement (ICE) in response to a bulk request in August 2025, a federal judge stepped in. In November 2025, Judge Colleen Kollar-Kotelly of the U.S. District Court for the District of Columbia granted a preliminary injunction, finding the data sharing likely violated federal law and halting further disclosures.

During the appeal of that injunction, the case took a material turn when the IRS filed a supplemental declaration from its chief risk and control officer, Dottie A. Romo. The Romo declaration was submitted “to modify certain prior statements” and admitted the IRS had provided addresses to ICE even when the requests were “either incomplete or insufficiently populated.”

To dig deeper, visit the original article on the Thomson Reuters blog.

Tax strategy implementation challenges: Why even the best plans fail

Nageshwaran Gopal — Mon, 30 Mar 2026 14:43:21 GMT

The gap between 'here's your tax plan' and 'here's your tax savings' is where thousands of dollars disappear every year.

Highlights

Tax strategy implementation fails when execution steps aren't clearly defined and followed through.
AI accelerates planning but cannot ensure deadlines, funding, or filing requirements are met.
Successful tax results require accountability systems linking strategy to executable, calendar-driven actions.

To dig deeper, visit the original article on the Thomson Reuters blog.

New Report Fuels Calls to Regulate Uncredentialed Tax Preparers

Neil Vicente — Mon, 23 Mar 2026 12:21:30 GMT

Preparer Oversight Constraints

“About 56% of the over 684,000 preparers registered with the IRS at the beginning of Calendar Year 2026 were non-credentialed,” according to the CTR. These preparers are not attorneys, CPAs, enrolled agents, or participants in the IRS’ voluntary Annual Filing Season Program (AFSP), the CTR explains, and are largely unregulated at the federal level.

This lack of oversight stems from Loving v. IRS (113 AFTR 2d 2014-867), a 2014 decision holding that the IRS lacks statutory authority to mandate competency testing and continuing education for preparers.

“Non-credentialed and ghost preparers have a significant compliance impact on low-income taxpayers,” according to the CTR. The group cites IRS data showing returns from non-credentialed preparers accounted for over 92% of the dollar adjustments in Earned Income Tax Credit (EITC) audits for tax year 2020.

To dig deeper, visit the original article on the Thomson Reuters blog.

Coca-Cola, DOJ at Odds Over 3M Blocked Income Ruling

Neil Vicente — Mon, 23 Mar 2026 12:18:28 GMT

Blocked Income

Generally, IRC § 482 allows the IRS to distribute, apportion, or allocate gross income, deductions, credits, or allowances among commonly controlled entities when needed to prevent tax evasion or clearly reflect income, including by requiring that returns from intangibles be commensurate with the income attributable to the intangible. The regulations describe the goal as determining the taxpayer’s true taxable income under an arm’s-length standard.

Treasury’s blocked-income regulation under § 482 requires that a foreign restriction be publicly promulgated and generally applicable to similarly situated controlled and uncontrolled parties and that it expressly prevents payment or receipt, in any form, of the arm’s-length amount. The guidance also distinguishes legal prohibitions on payment from rules that merely limit local deductibility.

To dig deeper, visit the original article on the Thomson Reuters blog.

Plan’s Dialysis Carve-Out Withstands HIPAA Nondiscrimination Challenge

Neil Vicente — Mon, 23 Mar 2026 12:13:25 GMT

A federal trial court has issued what could be the final decision in a long-running dispute between a large dialysis provider and a group health plan that classified all dialysis providers as “out-of-network,” resulting in a lower reimbursement rate for dialysis providers than for providers of other medical services.

The U.S. Supreme Court ruled in 2022 that the plan did not violate the Medicare Secondary Payer (MSP) rules by limiting coverage for outpatient dialysis, even though the treatment is used almost exclusively for patients with end-stage renal disease (ESRD). The case was sent back to the trial court, which dismissed the provider’s MSP claim in accordance with the Supreme Court’s ruling. However, the court did not dismiss a separate allegation that the employer, as plan sponsor, discriminated against participants with ESRD in violation of HIPAA’s health status nondiscrimination rules by eliminating network coverage for dialysis and exposing the participants to higher costs. The court also declined to dismiss the provider’s claim for benefits under ERISA § 502, to the extent it was based on the alleged HIPAA violation.

To dig deeper, visit the original article on the Thomson Reuters blog.

AICPA Proposes Revised Definition of ‘Attest Engagement Team’ in Ethics Code

Neil Vicente — Mon, 23 Mar 2026 12:09:36 GMT

The AICPA’s Professional Ethics Executive Committee (PEEC) on March 16, 2026, issued an exposure draft (ED) proposing revisions to the definition of “attest engagement team” in the Code of Professional Conduct to clarify its alignment with other AICPA professional standards.

This follows a decision made by the PEEC during a meeting on February 18 to release the proposal for public comment, according to the meeting agenda.

The ED would revise ET Section 0.400.05 in the code. If adopted, the revised definition would apply to CPAs in public practice.

To dig deeper, visit the original article on the Thomson Reuters blog.

Filing Status Optimization and SALT Limits

Joseph Tappe — Mon, 16 Mar 2026 13:07:46 GMT

I ran a filing status optimazation for a return. The return has wages, interest, dividends, taxes and mortgage interest. The analysis shows that MFS will save $2,400 in taxes compared to MFJ. That did not seem right to me. In looking further I saw the the software is not calculating the SALT limitation correctly for MFS.

The SALT limitation for MFJ is $30,505. The combined SALT limitation for MFS should be the same. However, UT per UT's calculation, the combined SALT deduction for MFS is $35,253.

Is anyone else seeing this?

Proposed IRS Regs Offer Alternate E-Furnishing Option for Digital Asset Broker Statements

Neil Vicente — Mon, 09 Mar 2026 14:58:05 GMT

Current Rules

Under the current rules for furnishing payee statements electronically, which are based on the framework established for Form W-2 under IRC § 6051, a broker must obtain affirmative consent from a customer before sending a tax statement electronically. This framework guarantees customers several key rights, including the right to receive a paper copy of the statement if they do not consent and the right to withdraw their consent at any time, after which the broker must revert to providing paper statements.

The nature of digital asset trading, which is conducted almost exclusively online, means that some customers engage in an extremely high volume of transactions. According to the proposed regs, this could result in a single customer’s annual Form 1099-DA, Digital Asset Proceeds From Broker Transactions, being hundreds or even thousands of pages long. The associated costs and logistical burdens of printing and mailing such voluminous documents were cited as potentially unmanageable for brokers.

To dig deeper, visit the original article on the Thomson Reuters blog.

Form 1099-DA Debut Will Test Broker, Taxpayer Readiness in Transition Year

Neil Vicente — Mon, 09 Mar 2026 14:56:01 GMT

Digital asset brokers and taxpayers are expected to face some growing pains with this tax season’s debut of a new crypto-specific information return, but the real test of the new reporting regime will come next year, according to a pair of veteran digital asset experts.

Deloitte Senior Manager Jonathan Cutler and Managing Director Seth Wilks told Checkpoint that while tax year 2025 will be a transitional period for Form 1099-DA, Digital Asset Proceeds From Broker Transactions, brokers and customers alike must stay on top of tracking gross proceeds before mandatory cost basis reporting is phased in for tax year 2026.

To dig deeper, visit the original article on the Thomson Reuters blog.

IRS Releases Schedule, Instructions for New OBBB Individual Deductions

Neil Vicente — Mon, 09 Mar 2026 14:42:01 GMT

The IRS has published new Schedule 1-A that taxpayers will use for tax year 2025 to claim the One Big Beautiful Bill Act (OBBB) deductions for tips, overtime, and car loan interest as well as the enhanced deduction for seniors. (IR 2026-28, 3/2/2026)

Schedule 1-A and its related instructions – included in the Form 1040 Instructions – allow taxpayers to deduct amounts for these new categories. Generally, taxpayers can claim these new deductions whether they claim the standard deduction or itemize their deductions.

To dig deeper, visit the original article on the Thomson Reuters blog.

Electronic Payment Instructions

Joseph Tappe — Tue, 24 Feb 2026 13:46:17 GMT

I want to have the federal estimated tax filing instructions to include language about making the payment electronically at IRS.gov. I do not see a custom paragraph for this. Is there one or is there box that can be checked to include this? Or do I need to create a custom paragraph?

Supreme Court tariff ruling in Learning Resources, Inc. v. Trump: What corporate tax and trade teams need to know

Neil Vicente — Mon, 23 Feb 2026 11:54:31 GMT

SCOTUS strikes down tariffs in new ruling

Highlights

Supreme Court ruled IEEPA does not authorize presidential tariff imposition on imports.
Decision invalidates billions in tariffs, potentially unlocking $175 billion in refunds.
Ruling shifts trade policy toward congressional action, requiring new compliance strategies.

In a landmark decision that reshapes the landscape of executive trade power, the Supreme Court of the United States has ruled 6-3 in Learning Resources, Inc. v. Trump (Case No. 24-1287) that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs on imported goods.

To dig deeper, visit the original article on the Thomson Reuters blog.