Parker Tax Pro Library

08/06/2026

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."

Siemens Medical Solutions USA, Inc. v. Comm'r, 167 T.C. No. 5 (2026).

07/30/2026

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. "Introductory Guidelines for Responsible AI Use in Federal Tax Practice," OPR Alert 2026-19."

OPR Alert 2026-19 (6/24/26).

07/22/2026

IRS Replaces First Time Abate with New Automatic Penalty Exemption Program

The IRS announced Automatic Exemption from Penalty (AEP), a new automatic process to provide relief from penalties for failure to file, failure to pay, and failure to deposit for taxpayers with a history of filing and paying on time. The AEP program, which applies to eligible original returns beginning with tax year 2025 and 2026 quarterly returns, will replace the long-standing First Time Abate administrative relief program and is designed to simplify the process and reduce the burden for those with a timely compliance history. IR-2026-83 (7/8/26); IRS Website - Administrative Penalty Relief.

IR-2026-83.

06/17/2026

Failure to Report Significant Wedding Gifts from Overseas Results in Large Penalty

Zhang v. IRS, 2026 PTC 108 (N.D. Cal. 2026).

05/28/2026

Final Regs Modify Partnership Reporting Requirements for Unrealized Receivables

"The IRS issued final regulations that modify information reporting obligations with respect to sales or exchanges of interests in partnerships owning inventory or unrealized receivables (i.e., Code Sec. 751(a) assets)."

https://www.parkertaxpublishing.com/public/APA-challenge-ESOP.html

05/26/2026

District Court Dismisses APA Challenge to IRS ESOP Information Request Procedure

"A district court dismissed a lawsuit brought by taxpayers that established an employee stock ownership plan (ESOP), arguing that the IRS violated the Administrative Procedure Act (APA) when it sent the ESOP a Form 4564, Information Document Request, stating that the ESOP was not qualified under Code Sec. 401(a) and the trust was not exempt under Code Sec. 501(a)."

https://www.parkertaxpublishing.com/public/APA-challenge-ESOP.html

05/21/2026

Taxpayer Advocate Encourages Taxpayers to Claim COVID-Era Refunds Before July 10

"In an April 30 blog post, the National Taxpayer Advocate stated that tens of millions of taxpayers may be entitled to refunds or abatements of penalties and interest the IRS assessed during the nearly 3.5-year COVID-19 federal disaster period if they file claims by July 10, 2026."

https://www.parkertaxpublishing.com/public/covid-era-refund-deadline.html

The National Taxpayer Advocate, April 30 blog post. Kwong v. U.S.

05/19/2026

Tax Court Won't Provide a Remedy for IRS Failure to Provide Estate Valuation Statement

"The Tax Court rejected an estate's motion seeking to preclude the IRS from asserting its determined value of the estate as a consequence of the alleged IRS's failure to provide a written statement explaining the basis of the valuation as required within 45 days of the estate's request under Code Sec. 7517(a)."

https://www.parkertaxpublishing.com/public/irs-estate-valuation.html

05/12/2026

Taxpayer Advocate Encourages Taxpayers to Claim COVID-Era Refunds Before July 10

"In an April 30 blog post, the National Taxpayer Advocate stated that tens of millions of taxpayers may be entitled to refunds or abatements of penalties and interest the IRS assessed during the nearly 3.5-year COVID-19 federal disaster period if they file claims by July 10, 2026."

https://www.parkertaxpublishing.com/public/covid-era-refund-deadline.html

04/30/2026

Court Rejects Proposed Settlement Allowing Churches to Endorse Political Candidates

"A district court held that it did not have jurisdiction to enter a proposed consent judgment, agreed to by the IRS two churches and two other nonprofit groups focused on religious practice, that would have declared unconstitutional the provision in Code Sec. 501(c)(3) that bars exempt organizations from participating in political campaigns (i.e., the Johnson Amendment). "

https://www.parkertaxpublishing.com/public/tax-anti-injunction-act.html

National Religious Broadcasters, et al. v. Bessent et al., 2026 PTC 76 (E.D. Tex. 2026).