Daily Perplexity scout across seven topic queries — IRS & Treasury guidance, federal tax legislation, FinCEN advisories, OFAC designations, SEC rules, state estate-tax changes, and significant Tax Court opinions. Default view shows the last 14 days, unreviewed first.
perplexity / sonar-pro
12 unreviewed · 18 total
Every item below is a news reference, not citable authority. These are signals worth investigating. Run the research against the primary-source corpus before drafting client advice.
Showing 11 of 18 items
Treasury and IRS released Notice 2026-24 expanding the anti-clawback safe harbor under Reg. §20.2010-1(c) for gifts made between 2018 and 2025 when the donor dies after the OBBBA exclusion sunset. The notice clarifies treatment of formula transfer clauses and split-interest charitable gifts. Comments due 60 days from publication.
FinCEN issued advisory FIN-2026-A002 reinstating CTA reporting obligations for domestic reporting companies after the Fifth Circuit's decision in Texas Top Cop Shop II. The advisory sets a 90-day extended deadline and clarifies the treatment of trust-owned reporting companies.
IRS released Rev. Proc. 2026-19 reproposing aggregation rules for qualified trades or businesses held through tiered partnerships. The procedure withdraws the 2024 proposal in light of comments and adopts a per-entity testing approach with a transition election for the 2026 tax year.
OFAC designated 47 additional individuals and entities under the Global Magnitsky and Russia-related authorities. Several designations target trust-and-corporate-service-provider intermediaries in offshore jurisdictions; practitioners should re-screen ultimate beneficial owners.
The Senate Finance Committee reported S. 1842 favorably on a 17-9 vote. The bill would index the GST exemption to inflation prospectively, eliminate the "Crummey" notice formality for trusts with under $5M of contributed property, and create a federal directed-trust safe harbor. Floor consideration expected this summer.
The SEC adopted amendments to Rule 506(c) providing a non-exclusive safe harbor for issuer verification of accredited-investor status using third-party trust and net-worth attestations. Compliance date 180 days from publication.
Connecticut enacted Public Act 26-31 raising the estate and gift tax exemption to $13.99M effective for decedents dying on or after January 1, 2027. The act also conforms the state exemption to whatever the federal exclusion is after the OBBBA sunset.
FinCEN released a proposed rule pushing the effective date for the investment adviser AML program rule from January 1, 2026 to January 1, 2027. Comments due 60 days from publication. RIAs serving high-net-worth and trust accounts should watch implementation guidance.
In Estate of Whitford v. Commissioner, T.C. Memo. 2026-48, the Tax Court held that a contemporaneous non-tax-purpose memorandum was insufficient to overcome §2036(a) inclusion where the decedent retained day-to-day control of FLP investments after formation. Follows Powell and Cahill in extending the implied-agreement analysis.
A bipartisan bill in the House would amend §1014 to clarify that assets held in a grantor trust at the grantor's death receive a §1014 basis adjustment, codifying the position previously rejected in Rev. Rul. 2023-2. Tax-writers from both parties signaled support.
OFAC issued General License 91A authorizing wind-down transactions through July 15, 2026 for trust structures containing newly designated Cayman-resident protectors. Practitioners with affected client structures should document compliance with the GL's reporting requirements.