Section Newsletters

Articles From Sandra D. Mertens

Here We Go Again: Challenges to FinCEN’s Residential Real Estate Rule By Sandra D. Mertens Federal Taxation, April 2026 An update to the FinCEN real estate Final Rule saga: The Eastern District of Texas ruled that FinCEN lacked statutory grounds for issuing its 2024 Final Rule. While the Final Rule is likely to continue to be litigated, attorneys, tax practitioners, and real estate professionals should carefully watch as courts interpret the applicable laws and regulations and FinCEN responds.
New Residential Real Estate Reporting to FinCEN Begins March 1, 2026 By Sandra D. Mertens Federal Taxation, March 2026 Effective March 1, 2026, a new regulation promulgated by the FinCEN requires a new information report each time a qualifying residential real estate transaction or settlement closes. The new regulation is the next step under the DOT’s longstanding effort to combat money laundering, terrorism financing, and other illicit financial activities. 
ISBA Midyear Meeting Highlights From the Federal Taxation Section By Sandra D. Mertens Federal Taxation, January 2026 The Federal Taxation Section Council met during the Joint Midyear Meeting to discuss business and issues relevant to the tax community, including the One Big Beautiful Bill Act. 
One Big Beautiful Bill Act: Tax Changes for 2026 for Large and Small Businesses By Sandra D. Mertens Federal Taxation, January 2026 The One Big Beautiful Bill Act brings many changes to provisions relating to businesses, including business taxes, incentives for rural and agricultural ventures, paid family and medical leave credit, business interest deductions, excess business loss limitations, bonus depreciation, and charitable contributions. 
One Big Beautiful Bill Act: Tax Changes for 2026 for Individuals, Families, and Estates By Sandra D. Mertens Federal Taxation, December 2025 The One Big Beautiful Bill Act contains several provisions that will impact tax law in 2026, including tax rates and tables, no tax on tips, no tax on car loan interest, senior bonus deduction, adoption credits, Trump accounts, and more. 
Tax Court Takes a Strict Stance on Procedural Deadlines Under the BBA Partnership Audit Rules By Sandra D. Mertens & Grace Symington Federal Taxation, November 2025 Recent Tax Court decisions, including JM Assets and Bayou Serpent, demonstrate strict enforcement of procedural deadlines. This strict adherence reinforces the importance of diligence and punctuality, safeguarding the integrity of the judicial process by emphasizing the necessity of complying with procedural requirements. 
2025 Illinois Tax Amnesty Programs Offer Opportunities for Penalty and Interest Relief to Taxpayers By Sandra D. Mertens & Grace Symington Federal Taxation, October 2025 Familiarize yourself with the 2 amnesty programs that will take effect in the fall of 2025 as a direct result of House Bill 2755, signed by Governor Pritker on June 16, 2025. 
Recent Changes to the IRS Office of Appeals By Sandra D. Mertens & Grace Symington Federal Taxation, October 2025 The Internal Revenue Service (IRS) Independent Office of Appeals is launching two initiatives aimed at increasing transparency and fairness to taxpayers: (1) a Post Appeals Mediation pilot program, and (2) making Appeals Case Memos available to share with taxpayers.
Tax Consequences of Settlement Agreements: Lessons From Mennemeyer v. Commissioner By Sandra D. Mertens Federal Taxation, September 2025 A case summary of the U.S. Tax Court matter, Adrienne Mennemeyer v. Commissioner of Internal Revenue, T.C. Memo 2025-80, and lessons learned on taxation of settlements. 
Roundup of Recent IRS Penalty Abatement Caselaw By Sandra D. Mertens Federal Taxation, June 2024 Summaries of several recent court decisions with interesting penalty abatement results.
U.S. Supreme Court to Decide Whether 2017 Mandatory Repatriation Tax Is Constitutional and Satisfies Due Process in Moore v. United States By Sandra D. Mertens Federal Taxation, March 2024 The Tax Cuts and Jobs Act of 2017 significantly changed portions of the U.S. tax code, including adding the Mandatory Repatriation Tax, which imposes tax on certain U.S. shareholders of foreign corporations.
The Corporate Transparency Act Will Be a Big Deal for Small Businesses By Sandra D. Mertens Federal Taxation, October 2023 On January 1, 2021, Congress enacted the Corporate Transparency Act, intended to prevent criminals from using companies for money laundering, corruption, tax evasion, drug trafficking, fraud, and other crimes.

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