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Proposed New IRS Reporting Requirements for Nonprofit Hospitals

A Congressional discussion draft released May 12, 2026, would significantly expand the information that tax-exempt hospitals must report annually on their Form 990. The draft amends Section 6033 of the Internal Revenue Code by adding a new subsection (p) and would apply to every organization described in IRS Code Section 501(r)(2) that is required to…

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IRS Issues Guidance on 100% Depreciation for Commercial Real Estate

The Internal Revenue Service (IRS) has released interim guidance in Notice 2026-16, outlining a major new tax incentive for the manufacturing sector. The guidance implements a 100% special depreciation allowance under IRC §168(n) for certain commercial real property classified as Qualified Production Property (QPP). This provision—enacted as part of the One Big Beautiful Bill Act…

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Treasury Signals Increased Scrutiny on QSBS Trust “Stacking” Strategies

Treasury Department officials are discussing their concerns with Qualified Small Business Stock (QSBS) “stacking” strategies. Concerns were raised about stacking at two recent conferences; one official brought it up at the May meeting of the American Bar Association’s Tax Section, and another at a law firm-sponsored conference. Under the QSBS rules, each “taxpayer” is entitled…

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The IRS Appeals Kwong: What It Means for Taxpayers, COVID-Era Interest and Penalty Relief and Why Waiting May Be Risky

The appeal many expected has arrived, but the real question is what comes next. For months, taxpayers and practitioners have wondered whether the IRS would ultimately accept the implications of Kwong v. United States or continue defending its interpretation of the COVID-era relief provisions under IRC §7508A(d). We now have part of that answer. The…