2026-07-13 A Week of Final Regulations

This week we look at:

Transitioning from First Time Abate (FTA) to Automatic Exemption from Penalty (AEP)

Strict Enforcement of Tax Refund Statutes of Limitations

Employee Retention Credit (ERC) Refund Claims & Pleading Standards

Pandemic-Era Persistence of New York's Convenience of the Employer Rule

Invalidity of Treasury Regulation Section 1.951A-2(c)(5)

Non-Shareholder Capital Contributions vs. Compensation

Final Section 1035 Exchange & Corporate Reorganization Regulations

Reclassification of Abusive CRAT Structures as Listed Transactions

The National Taxpayer Advocate's Perspective on AEP