Access to Justice in Tax Law: Recent Jurisdictional Pathways and BarriersBy Sandra D. MertensFederal Taxation, September 2026Tax practitioners are familiar with the complex nature of navigating the administrative processes of the IRS in an attempt to reach a truly neutral decision-maker: The Tax Court or other adjudicative body. Jurisdiction is often the most common barrier to a client’s “day in court” when it comes to tax issues, with the Tax Court or federal district courts often dismissing a case for lack of jurisdiction because the taxpayer did not meet one of the myriad of procedural or time-governed requirements. Several recent cases highlight key arguments for taxpayers, as well as a few warnings.
Illinois Becomes the Most Recent State to Decouple From Federal QSBS Tax TreatmentBy J. Christian ManalliFederal Taxation, September 2026On June 16, 2026, Illinois passed legislation decoupling the state’s income tax from the federal exclusion for gain from the sale of Qualified Small Business Stock (QSBS) under IRS Code Section 1202. The change is effective for tax years ending on or after Dec. 31, 2026.
IRS & FinCEN Tax News Updates From August 2026By Sandra D. MertensFederal Taxation, September 2026A compilation of updates from the IRS and FinCEN, including digitally authenticated Tax Compliance Report; reminder of the Report of Foreign Bank and Financial Account filing obligations; a final rule that premanently removes the requirement for U.S. companies and U.S. person to report beneficial ownership information to FinCEN; and more.
The One About Passing AI Costs Through to ClientsBy Carolyn ElefantFederal Taxation, September 2026The question presented in this inaugural MyShingle Ethics Opinion: May lawyers pass the costs of artificial intelligence, from subscriptions and platform licenses to metered per-token usage charges, through to clients, and should they? The view of this Opinion is that firms should absorb all AI-related costs as overhead subject to two narrow situations only: extraordinary single-matter consumption that functions like an outside vendor charge, and tools the client directs the lawyer to use.
Illinois’ Remote Retailer Tax Amnesty Program Begins August 1stBy Sandra D. MertensFederal Taxation, July 2026Last year, the IRS announced the 2026 Remote Retailer Tax Amnesty Program which presents a limited time opportunity for remote retailers to resolve past Illinois sales tax liabilities without associated penalties and interest. The program will run from August 1st through October 31st, 2026, which is the time period during which the Remote Retailer Tax Amnesty Application must be submitted.
Save the Date for ISBA’s Solo & Small Firm Conference in PeoriaFederal Taxation, July 2026Join your fellow Federal Taxation Section members in Peoria on September 17–18, 2026, for the ISBA Solo & Small Firm Conference, From Log Cabin to Legacy: Growing and Sustaining a Solo or Small Firm in Illinois.
Using AI in Federal Taxation PracticeBy Sandra D. MertensFederal Taxation, July 2026While even the IRS admits the powerful potential in AI to streamline routine tasks, enhance research, and provide valuable insights, final decisions must always rest with a qualified tax professional who understands the complexities of tax law and ethical standards.
June Report From IRS Liaison OfficeFederal Taxation, June 2026A compilation of IRS practitioner updates, shared by IRS agent Danarnell Belarmino, Stakeholder Liaison Area 3 (Chicago), on June 2, 2026.
Report on the Committee’s 2026 Washington, D.C. TripBy Michael DuhnFederal Taxation, June 2026On May 7-8, 2026, delegates from the Federal Taxation Committee met with Congression representative offices to discuss potential changes in tax law to exclude farmers from the concept of "constructive receipt" regarding delivery and payment of their crops to their respective elevators.
What You Should Know About Kwong, Abdo, and the July 10, 2026, Deadline to Claim Covid-Era Tax RefundsBy Sandra D. MertensFederal Taxation, June 2026A series of recent court decisions highlight a unique opportunity for taxpayers to claim certain refunds or abatements of penalties and interest for tax return filing and payment deadlines from January 20, 2020, through July 10, 2023. This article provides a summary overview of the key statutes, judicial opinions, and arguments, as well as steps that must be taken by no later than July 10, 2026, to take advantage of the developments.
The Education Freedom Tax Credit of the OBBBABy Philip D. SpeicherFederal Taxation, May 2026One of the lesser discussed provisions of 2025’s One Big Beautiful Bill Act is the Education Freedom Tax Credit (“EFTC”). The EFTC provides a federal tax credit for contributions to approved scholarship organizations who provide funding for various educational resources, including private school tuition, tutoring, special education services, and other elementary and secondary education expenses.
Transferee Liability for Unpaid Estate Taxes Can Haunt Fiduciaries and Beneficiaries for DecadesBy Sandra D. MertensFederal Taxation, May 2026The IRS typically does not decide to audit a Form 706 until nine months after the filing date. Moreover, since 2021, estate tax closing letters are not routinely issued, but must be specifically requested with a fee payment. For these reasons, executors and trustees should make sure to work closely with a tax return preparer knowledgeable about estate taxes who can properly advise about the payment deadlines, closing procedures, and consequences for non-payment.
Here We Go Again: Challenges to FinCEN’s Residential Real Estate RuleBy Sandra D. MertensFederal Taxation, April 2026An 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.
Mark Your Calendars…Federal Taxation, March 2026Don't miss these upcoming events!
New Residential Real Estate Reporting to FinCEN Begins March 1, 2026By Sandra D. MertensFederal Taxation, March 2026Effective 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.
Spotlight on Section Member Kathryn GarlowFederal Taxation, March 2026Learn more about Section Council Member, Kathryn Garlow, including her career trajectory, interests in tax law, and her hobbies.
ISBA Midyear Meeting Highlights From the Federal Taxation SectionBy Sandra D. MertensFederal Taxation, January 2026The 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 BusinessesBy Sandra D. MertensFederal Taxation, January 2026The 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.
ISBA Leadership OpportunitiesFederal Taxation, December 2025Interested in serving on an ISBA Section Council? Be sure to self-nominate prior to the nomination deadline of January 15, 2026!
One Big Beautiful Bill Act: Tax Changes for 2026 for Individuals, Families, and EstatesBy Sandra D. MertensFederal Taxation, December 2025The 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.
What Is Mediation and ADR: History, Models, and PrinciplesBy Sandra Crawford, J.D.Federal Taxation, December 2025An overview on the origins of mediation and alternative dispute resolution, different models of mediation, and the core principles of mediating disputes.
An Appearance of Impropriety in Administrative HearingsBy Alan RhineFederal Taxation, November 2025This article explores the role of administrative law judges and analyzes the possibility of bias or the appearance of impropriety under the Illinois Code of Judicial Conduct of 2023.
Tax Court Takes a Strict Stance on Procedural Deadlines Under the BBA Partnership Audit RulesBy Sandra D. Mertens & Grace SymingtonFederal Taxation, November 2025Recent 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.
Why I Seek Out Rooms Without Lawyers—And Why You Might TooBy Ricardo SantiagoFederal Taxation, November 2025Learn about the benefits of networking outside of your usual professional circles and challenge yourself to network with non-attorneys to grow your practice.
