New York City second-home owners, including trusts and LLCs, have until Oct. 13 to claim an exemption from the pied-à-terre surcharge, after an appeals court stayed a ruling that had cancelled the city’s notices. Plus a Trump account comment request, a Senate bill to uncap 529-to-Roth rollovers, and a pending trust company acquisition.

California’s Franchise Tax Board says it must be ready to administer a billionaire tax within six months of passage, and residency lawyers warn that paper moves will not hold up. Plus a Tax Court decision on partner basis and at-risk amounts, an IRS and HMRC whistleblower partnership aimed at offshore trusts, and an Oct. 20 Trump account comment deadline.

A federal court says the IRS had no authority to abate a foreign gift penalty once the refund suit went to the Justice Department. Plus a revised staking safe harbor for crypto trusts, the taxpayer service bill’s Senate passage, a California partnership sourcing decision, and two gift and charitable trust filing deadlines.

The IRS grants spouses more time to allocate GST exemption after a preparer mistakenly opted out of automatic allocation on split-gift returns. Plus late portability relief, two tax administration bills cleared for the President, the new charitable deduction floor, and the Dolly Parton estate dispute.

A California appellate court holds that filing and withdrawing a trust contest can still trigger a no contest clause. Plus the Tax Court on Form 872 extensions, new scholarship credit regulations, SEC proposals on crypto custody and private markets, and Trump account auto-enrollment.

Temporary Trump account regulations let private foundations and DAFs fund accounts for broad classes of children, with built-in expenditure-responsibility cover. Plus the 2026–2027 Priority Guidance Plan, 71 obsoleted rulings, a 40% captive penalty, and a divorce decree that left an ex-spouse’s half exposed to an IRS lien.

The IRS treats § 351 ETF conversions as taxable exchanges and flags exchange funds, box-spread ETFs, and tax-aware character trades as potentially abusive. Plus the Tax Court voids an offer in compromise accepted after the taxpayer’s death, proposed § 1062 farmland installment rules, and a cap on trust fund penalty collection.

Treasury finalizes a $76 estate tax closing letter fee effective Oct. 26; Sixth Circuit shields Chase from a trust beneficiary’s suit; IRS seeks $736 million over GRATs paid with forgiven notes.

A federal court rejects an executor’s refund claim built on a decedent’s carried-back partnership loss after excluding the family’s only participation evidence. Plus the IRS seeks comments on post-OBBBA Opportunity Zone rules, the Tax Court refuses to void an easement FPAA over Appeals access, and a new ACTEC Law Journal article on QSBS stacking.

The Tax Court holds for the first time that the BBA partnership petition deadline can be equitably tolled, rescuing a late petition filed after the IRS told counsel no final adjustment had been mailed. Plus the October section 7520 rate rises to 5.6 percent, the IRS extends section 871(m) relief through 2028, and two Texas decisions on trust receiverships and fiduciary limitations.

The Second Circuit affirms Soroban, deepening the circuit split over whether active partners in state-law limited partnerships owe SECA tax; the House passes theft-loss relief for fraud victims; the Tax Court sustains fraud penalties that survive bankruptcy discharge; and the SEC opens a path for tokenized stock trading.

Our population is aging, and the risk of financial exploitation continues to increase. Elder theft and elder scams continue to be an unfortunately common occurrence. Financial exploitation of seniors threatens the autonomy, security, and dignity of some of our population’s most vulnerable. Effective estate and disability planning reduces the risk of financial exploitation of seniors by establishing a foundation of documents and representatives before a crisis occurs. Taking proactive measures such as establishing a well-drafted financial power of attorney and health care directive minimize the opportunity for abuse and exploitation, with the right representatives. Periodic reviews and updates to estate and disability planning documents also help to ensure the planning aligns with the client’s needs and circumstances. Effective estate and disability planning promotes autonomy and streamlines authority while the client is alive, but also after they pass away.

QOF investors face mandatory gain recognition on Dec. 31, 2026 — plus Tax Court rulings on §6751(a) penalty notices and lien withdrawal, drought livestock relief, and probate finality scholarship.

An estate plan can work exactly as structured while the business inside it fails. A business is different from most other assets inside an estate. Its value may depend on the owner continuing to lead, make decisions, maintain relationships, or simply keep things moving. When that owner dies or becomes incapacitated, transferring ownership may be only part of the problem. Estate planners do not need to become business succession experts. But when a meaningful portion of an estate is tied up in an operating company, they should recognize the assumptions the estate plan makes about that company. A Business Estate Plan addresses four of them: emergency continuity, governance, ownership mechanics, and strategic intent.

DHS’s new F-1/J-1 admission rules take effect today, with tax-residency traps immigration counsel may miss. Plus: an IRS ruling saves a GST-exempt trust from a scrivener’s error, ESBT trustee relief, S corp and §754 election extensions, two exemption denials, early 2027 bracket projections, and more.

Today's Tax Court decision in Tunkl v. Commissioner is a cautionary tale on documenting informal loans and joint ventures, alongside new proposed IRS regulations on QOF reporting and foreign-source deduction allocation.

The Tax Court holds in Katanga Properties that a Form 872–M consent extends the entire BBA adjustment period, leaving the 330-day post-NOPPA mark no safe harbor. Plus Zollars on extension strategy, La Torre Jeker on whether AI can supply reasonable cause against Form 3520 penalties, and Kitces on client directives you disagree with.

Unsealed probate filing finds Rupert Murdoch's trust restructuring was a bad-faith effort to favor one beneficiary; North Carolina codifies de novo review for agency interpretations; Fourth Circuit affirms a $2.9 million willful FBAR penalty; plus new trust, probate, and Tax Court decisions from California, New Hampshire, Idaho, and the Eleventh Circuit.

PRIMARY LAW Racial Nondiscrimination in Private Schools, REG-119986-25 (Federal Register) Treasury and the IRS proposed a new Treas. Reg. § 1.501(c)(3)-2 providing that a private school is not operated exclusively for exempt purposes if it adopts, maintains, or enforces any policy or practice that discriminates on the basis of race, color, or national or ethnic origin — with discrimination defined to include discrimination “for any purpose” — and would delete the second sentence of section 3.02 and the third and fourth sentences of section 4.05 of Rev. Proc. 75-50, which currently provide that financial assistance programs favoring racial minority groups do not adversely affect exempt status; comments are due November 3, 2026, and the rules would apply to tax years beginning after May 31, 2027.

Carl Sagan's estate sues Luma AI over a synthetic voice in a product ad, raising postmortem persona rights as an estate planning question. Plus: the Tax Court reaches the merits in Berenblatt, the SEC proposes its first transfer agent overhaul in 40 years, and the Buss family trust fails to keep the Lakers in the family.

Revenue Procedure 2026-3 expands the categories of issues for which taxpayers cannot obtain advance guidance from the Internal Revenue Service, including clean energy investment incentives, worker-classification questions, trust modifications, and other transactions that frequently involve substantial financial commitments and legal uncertainty. Although framed as a procedural update, the revenue procedure has significant implications for tax administration because it limits access to one of the primary mechanisms through which taxpayers obtain certainty before engaging in complex transactions. This Note argues that expanding the no-rule regime reflects a broader shift away from prospective administrative guidance and toward a system in which taxpayers bear greater responsibility for interpreting ambiguous provisions and managing legal risk. In an environment where courts play an increasingly important role in resolving statutory ambiguity, this transfer of interpretive responsibility threatens uniformity, increases compliance costs, and makes tax outcomes more dependent on litigation and private analysis. To address these concerns, the Note proposes reforms including expanded safe harbors, broader published guidance, targeted rulings, and greater transparency regarding decisions to withhold guidance.

Federal Circuit holds the NIIT can’t be offset by a treaty-based foreign tax credit, a Texas court upholds jurisdiction over an out-of-state trustee, plus 9 new IRS written determinations and today’s practitioner commentary and news.

Court of Federal Claims limits treaty exemption for charities investing through pooled foreign funds, plus new Tax Court opinions on whistleblower awards, hobby-loss, and civil fraud, IRS enforcement priorities, and more in today's Daily Update.

Treasury and IRS release proposed regulations (REG-115646-25) under the OBBBA overhauling how U.S. shareholders calculate CFC pro rata shares of subpart F income and GILTI; the Eleventh Circuit affirms an easement deduction crushed to basis in Mill Road 36 Henry; an IRS private letter ruling grants section 1362(f) relief after six trusts missed ESBT election deadlines; California slayer statute spotlights New York common-law slayer rule; and more.

The IRS denied tax-exempt status to six organizations in one release, granted two portability election extensions, resolved three inadvertent S corporation terminations, and released September AFRs, plus practitioner commentary on AI privilege risk, advisory-firm M&A, and more.