Sneaky Developments in a Year with Few Developments - TCJA Provisions Expiring in 2025 and Major 2024 US Supreme Court Tax Decisions - virtual

In many ways you might see 2024 as the year not much happened in terms of tax developments, as Congress for the second year in a row has enacted no significant tax legislation, with this Congress at risk of being the first Congress in a long time to have enacted no tax legislation. But there are some developments that took place, especially a series of Supreme Court decisions at the end of their term that either were tax cases or have a key impact on taxation. The IRS continued to move forward with their program to attempt to deal with the flood of ERC claims that are backlogged and issued final regulations on minimum distributions. Finally 2025 is the final year for many changes made by the Tax Cuts and Jobs Act to be part of the law.

• The Supreme Court proclaims the end of Chevron deference:  what the Loper Bright decisions means in terms of challenges to IRS regulations, what practical effect will it have on your client's issues arising with the IRS in the near term, and what are likely implications of this change in analyzing regulations by courts going forward.
• The Supreme Court's decision in the Connelly case regarding the estate tax impact of life insurance redemption agreement in closely held corporations and partnerships:  Why this makes such arrangements potentially very disadvantageous if any shareholder is likely to have a taxable estate, how such arrangement could be restructured to be cross-purchase arrangements and the reasons why such arrangements could be impossible or simply not likely practical for many closely held entities.
• What is the real meaning of the Miller decision - did it decide whether realization is required for income to be taxed, why the case was meant to force the Court to rule whether a proposed wealth tax is constitutional and why the Court is not nearly as united as the count of those voting for the result ordered in this case might lead you to believe.
• Will the Supreme Court finally resolve the issue of whether the Corporate Transparency Act is constitutional and when would that likely take place if they do?
• What provisions are expiring from the Tax Cuts and Jobs Cuts at the end of 2025, what would the projected cost or revenue raised be if various provisions are renewed permanently, why those revenue scores may matter to members of Congress and what tax planning should be undertaken in the face of such extreme uncertainty?
• A look at the status of the IRS processing of employee retention credit claims for refund, the special programs the IRS is operating to allow some employers to either withdraw their claim or return the refund the employer already received and court cases that are challenging how the IRS is handling this program

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