AT Think

In the blogs: Breathing room

Private equity in the profession; green cards and exit taxes; governance for preparers; and other highlights from our favorite tax bloggers.

Breathing room

  • Current Federal Tax Developments (https://www.currentfederaltaxdevelopments.com/): The critical updates of Notice 2025-33, which impacts digital asset brokers and their compliance obligations under IRC Sections 6045, 3406 and related penalty provisions, extend and modify previously granted transitional relief, "offering much-needed breathing room."
  • Sovos (https://sovos.com/blog/): The IRS will decommission the Filing Information Returns Electronically system in January 2027; all 2026 returns will need to use the new IRS Information Returns Intake System. The window for preparation is closing fast. 
  • Institute on Taxation and Economic Policy (https://itep.org/category/blog/): State legislatures are enjoying a quiet time now, a temporary calm before the storm of the federal tax and budget debate begins raging again.
  • Tax Foundation (https://taxfoundation.org/blog): Illinois policymakers should think twice before taxing GILTI.

Simplify, simplify, simplify

  • Mauled Again (http://mauledagain.blogspot.com/): Why hasn't the blogger been commenting on the federal legislation that would extend and enlarge tax cuts and tax breaks for wealthy individuals and corporations? The answer is simple. 
  • TaxProf Blog (http://taxprof.typepad.com/taxprof_blog/): The contours of the Supreme Court's dormant Commerce Clause doctrine of internal consistency, which asks whether a state tax intrinsically overreaches in imposing a burden upon interstate commerce, are difficult to understand. A recent paper examines how uncertainty is suggested again by Zilka v. Tax Review Board
  • The Rosenberg Associates (https://rosenbergassoc.com/blog/): Private equity entered the accounting profession with promises of creating value and fixing many of the pain points in the profession. A recent survey shows that while PE is already delivering on some of those promises, mixed feelings (and warning signs) abound.
  • Wiss (https://wiss.com/insights/read/): The recent Tax Court decision in Soroban Capital Partners LP v. Commissioner has rippled through the financial and legal communities and reinforced the importance of functional roles over formal titles when determining tax liability under self-employment tax.
  • Virginia – U.S. Tax Talk: (https://us-tax.org/about-this-us-tax-blog/): When a foreign national works in the U.S. and is granted stock options, taxation of these options can become complex if the individual later leaves the U.S. and becomes a nonresident alien for tax purposes. 

Think about it

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