Parker's Latest Federal Tax Articles:
OCTOBER 2026
Proposed Regs Would Implement OBBBA Changes to Premium Tax Credit.
The IRS issued final regulations under Code Sec. 6311 regarding the payment of tax by commercially acceptable means. The final regulations, which reflect changes to the law made by the Taxpayer First Act in 2019, allow the IRS to directly accept payments of tax by credit or debit card, without having to connect taxpayers to third-party payment processors; the final regulations also remove restrictions on the payment of any fee by the IRS under any contracts related to payment of taxes by credit, debit, or charge card, and on the IRS imposing any fee or charge on persons paying taxes by credit or debit card. T.D. 10060.
Final Regs Allow IRS to Directly Accept Payments by Debit or Credit Card.
The IRS issued proposed regulations under Code Sec. 36B that would amend the regulations regarding an individual taxpayer's eligibility for a premium tax credit (PTC), the computation of a PTC, and an individual's tax liability due to excess advance payments of the PTC. The proposed regulations would affect taxpayers who enroll themselves or a family member in individual health insurance coverage through a Health Insurance Exchange and may be allowed a PTC for this coverage. REG-101576-26.
District Court: Government Cannot Reverse Abatement of Penalty by IRS.
A district court held that the government could not abate a taxpayer's penalty and then reinstate it after finding the abatement had been a mistake because the case had already been referred to the Department of Justice. The district court rejected the government's argument that the abatement was an unauthorized compromise under Code Sec. 7122(a) which the government could reverse. Groves v. U.S., 2026 PTC 288 (N.D. Ill. 2026).
Social Security Benefits Increase 3.6 Percent for 2027; Wage Base Grows by 4.23 Percent.
The Social Security Administration announced that social security and supplemental security income (SSI) benefits for approximately 76 million Americans will increase 3.6 percent in 2027. The amount of earnings subject to social security tax will increase from $184,500 to $192,300. Social Security 2027 Fact Sheet.
SEPTEMBER 2026
IRS Issues Automatic Consent Procedures for Research and Experimental Expenditures.
The IRS issued procedures under Code Sec. 446 and Reg. Sec. 1.446-1(e) for obtaining automatic consent to change methods of accounting for research or experimental expenditures...
AUGUST 2026
Tax Court Invalidates GILTI Reg That Limits Dividends Received Deduction.
The Tax Court held that the United States subsidiary of a German healthcare products company was entitled to claim a 100 percent dividends received deduction (DRD) under Code Sec. 245A for a dividend received from a foreign source, despite the fact that Reg. Sec. 1.245A-5T limits the deduction by 50 percent for certain extraordinary dispositions.
JULY 2026
IRS Provides Introductory Guidelines for Responsible Use of AI in Federal Tax Practice.
On June 24, the IRS Office of Professional Responsibility issued a bulletin on the responsible use by federal tax practitioners of artificial intelligence (AI). The bulletin highlights the risks of irresponsible AI use and provides a list of best practices for tax practitioners to integrate AI into their workflows.
JUNE 2026
IRS Issues Guidance on Qualified Long-Term Care Distributions.
The IRS issued a notice to provide guidance on qualified long-term care distributions under Code Sec. 401(a)(39), which are permitted to be made by defined contribution plans under the SECURE 2.0 Act of 2022 (Pub. L. 117-328).
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