Key Takeaways
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More on the new IRS CEO.
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Why not a new Commissioner?
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IRS cyber crime leader named acting compliance chief.
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Shutdown Day 7: negotiation hints, but no obvious progress.
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Trump announces 25% tariffs for medium and heavy trucks start November 1.
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Replace property taxes with... what?
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Supreme Court nice try department.
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National Fruit At Work Day.
Today! Tune in at 1:00 p.m. Central for R&D Incentives: What Leaders Across Industries Need to Know, featuring leaders of the Eide Bailly research incentives team. Register here.
Social Security Chief Adds Duties As Inaugural CEO Of IRS - Asha Glover, Law360 Tax Authority ($):
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The IRS has seen a series of leadership changes since President Donald Trump took office in January. Bessent, who is currently serving as the agency's acting commissioner after Billy Long was ousted from the position less than two months after being confirmed by the Senate, is the seventh person to lead the IRS this year. Trump has not yet named a new commissioner nominee.
Unlike the IRS commissioner, the newly created CEO position is not subject to Senate confirmation.
Bisignano To Do Double-Duty As Social Security Commissioner And New IRS ‘CEO’ - Kelly Phillips Erb, Forbes:
If you’re reading this and doing a double take, you didn’t misread it, and I didn’t report it incorrectly. According to the Treasury, this is a “newly created position.” As part of his new CEO duties, Bisignano will report directly to Bessent, managing the organization and overseeing all day-to-day IRS operations while also continuing to serve in his role as Commissioner of the Social Security Administration.
If that sounds a lot like the work of the IRS Commissioner, you’re not wrong. According to the IRS’s own manual, “The IRS Commissioner is tasked with establishing and interpreting policies related to tax administration, as well as developing strategic issues, goals, and objectives for the management and operation of the IRS. This role includes the overall planning, directing, controlling, and evaluation of IRS policies, programs, and performance.”
Bessent Taps Social Security Chief as First-Ever CEO of IRS - Benjamin Valdez, Tax Notes ($):
“President Trump is inventing positions out of thin air to bypass Congress and hand more power to his loyalists,” Neal said. “Putting Commissioner Bisignano in charge of the IRS while he simultaneously oversees a chaotic and destructive operation at Social Security makes it clear that in Trump’s Washington, loyalty is rewarded, and competence is irrelevant.”
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Michael Kaercher of the New York University Tax Law Center, echoing similar concerns about Bisignano’s charge of two large agencies, pointed to the potential for data sharing conflicts.
IRS Names New Acting Compliance Boss
IRS Cyber Crime Executive Named Interim Compliance Chief - Kat Lucero, Law360 Tax Authority ($):
As new acting chief tax compliance officer, Jarod Koopman will manage eight divisions, including IRS Criminal Investigation, where he has held the role of executive director of cyber and forensics services since 2021. The other seven divisions under Koopman's supervision include Large Business and International, Small Business/Self-Employed, Tax-Exempt & Government Entities, the Office of Professional Responsibility, the Return Preparer Office and the Whistleblower Office, according to the IRS announcement.
Koopman succeeds Edward Killen, who was appointed acting chief tax compliance officer earlier this year after his predecessor, Heather Maloy, retired from the IRS. Killen will return to his post as the agency's commissioner of the tax-exempt and government entities division, according to an IRS representative who requested anonymity. Killen was first appointed commissioner of the tax-exempt division in 2022.
IRS Selects New Acting Tax Compliance Chief - Benjamin Valdez, Tax Notes ($):
Kathy Enstrom of Moore Tax Law Group LLC, a former CI executive, praised Koopman’s move, saying he grew “into an outstanding leader within IRS Criminal Investigation.”
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The IRS has been without a permanent chief tax compliance officer since the retirement of Heather Maloy in March. The role was created in 2023 under the first revamp of the agency’s organizational structure in decades.
Still Shut
Government shutdown enters Day 7 as Trump signals shift in negotiations. - Joey Garrison, USA Today:
But in a significant shift, President Donald Trump is now expressing openness to one of Democrats’ main policy demands – that expiring subsides in the Affordable Care Act be extended.
"If we made the right deal, I’d make a deal. Sure," Trump said Monday when asked by a reporter whether he’s willing to make a deal with Democrats on the expiring Obamacare subsidies for lower-income families.
Shutdown enters Day 7 with no movement - Burgess Everett, Semafor. "John Thune is not changing his tactics after the fifth failed vote on the House-passed continuing resolution."
Shutdown Day 7: Dems say they can withstand Trump's threats - Andrew Desiderio, Jake Sherman, John Bresnahan and Max Cohen, Punchbowl News:
The Senate is expected to vote again today on the House-passed CR. And it’ll almost certainly fail.
Schumer said this should make it clear to Republicans that their clean CR has no path forward and that Democrats aren’t buckling.
Tariffs and Trade Tuesday
Donald Trump says US truck imports to face 25% tariff from November 1 - James Politi and Ilya Gridneff, Financial Times:
Trump announced the step in a Truth Social post on Monday, on the eve of a visit to the White House by Mark Carney, the prime minister of Canada, which would be heavily affected by any new tariffs on US truck imports.
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The White House has not offered any details on the truck tariffs, including whether vehicle parts would be affected and whether imports from Canada and Mexico would be exempt if they are compliant with the domestic content rules in the existing free trade agreement between the North American neighbours.
Trump to Unveil Farmer Aid as China Shuns U.S. Crops - Alan Rappeport and Kevin Draper, New York Times:
It is 2018 all over again as the Trump administration prepares to address the same policy crisis it faced seven years ago when President Trump, who imposed stiff tariffs on Chinese imports, had to shield the U.S. agriculture industry from the fallout of his trade war.
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The need for federal farm aid demonstrates the limits of Mr. Trump’s trade agenda, which relies on tariffs to gain leverage in trade negotiations that are intended to open up markets to U.S. exports. Instead, the tariffs have pushed up costs for American farmers, who are facing higher prices for fertilizer and equipment. At the same time, they have lost their biggest customer.
US Transfer Pricing Documentation: Protective and Practical - Chad Martin, Eide Bailly:
Platinum vs. Gold
A golden opportunity? - Toby Eckert, Politico Weekly Tax:
Trump has also proposed, but not set into motion so far, a Platinum Card that would cost $5 million. The revenue generated from both cards would be used “to promote commerce and American industry,” according to Trump’s order.
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U.S. residents are required to pay taxes on both their domestic income and money they earn abroad, a system known as worldwide taxation. But Platinum Card buyers would be allowed to spend up to 270 days in the U.S. without having to pay U.S. taxes on income they earn outside the country, according to the plan Trump has laid out.
Gold Card holders, however, would have to pay U.S. tax on their worldwide income if they are in the U.S. for at least 183 days over a three-year period.
Related: Eide Bailly Global Mobility Services.
Research Costs After OB3
Section 174 R&E Expenses Can Now Be Fully Expensed: Next Steps for Taxpayers - Jesse Wutkee, Eide Bailly
Foreign R&E remains capitalized and amortized over 15 years under Section 174. Procedural guidance for adopting this change was released recently through Revenue Procedure 2025-28 (the guidance).
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Options available to taxpayers for tax filing in 2024 depend on the taxpayer’s gross receipts and tax shelter status. A “small business taxpayer” meets the 448(c), three-year average annual gross receipts test of $31 million or less, for its first tax year beginning after December 31, 2024.
Hate Property Taxes? Compared to What?
There’s No Good Way to Pay for Property Tax Repeal - Jared Walczak, Tax Foundation:
The article discusses problems with replacing local property tax revenue with a statewide tax:
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Using Nebraska as an example, note that high rates in Omaha, Lincoln, Grand Island, and Scottsbluff yield high subsidies to their counties, while most of the state’s remaining counties emerge as losers. In the extreme, the county of Keya Paha would see its tax burden increase by 120 percent if it were forced to contribute an equalized share, while Douglas County (Omaha) would see a 23 percent tax reduction.
Blogs and Bits
SSA chief Bisignano named new IRS CEO - Kay Bell on Substack. "The IRS CEO post also assigns those key agency operational duties to another Trump administration loyalist."
‘Don’t Pay Me, Pay My Charity’ Worked For Trump, Will IRS Agree? - Robert Wood, Forbes. "In some cases, a plaintiff’s request to have settlement funds paid to charity are viewed by the IRS as a payment first to the plaintiff, and then a contribution by him to charity."
IRS Explains Process for Partnerships to Fix Employee Retention Tax Credit Errors - Parker Tax Pro Library. "The Chief Counsel's Office advised that the answer depends on the tax year in which the IRS refunded or credited the ERTC to the partnership."
Recent Tariffs Threaten Residential Construction - Elena Spatoulas Patel, Robert McClelland, and John Wong, TaxVox. "Using TPC’s tariff model, we calculated that current tariffs, including those just announced, will add roughly $30 billion to the costs of investment in residential structures."
Supreme Effort
The Supreme Court gets to pick which cases it will hear. It doesn't pick many tax cases. The cases it rejects often include "tax denier" cases involving individuals sovereign citizens who claim that the income tax is invalid or otherwise doesn't apply to them.
This year's batch of Supreme Court rejections includes a Georgia teacher who seems committed to the tax denier life, reports Tax Notes' Patrice Gay in Supreme Court Won’t Review Tax Liability Challenges, Convictions ($; I have omitted the teacher's name):
In his petition to the Court, Teacher made various arguments, including his claim that using employer reported payments to calculate income is illegal.
It went no better for an accountant who made arguments along the same lines.
The moral? The income tax is real, whether we like it or not. I hope this guy doesn't teach math or accounting.
What day is it?
It's National Fruit At Work Day. Fortunately banana splits involve fruit.
Make a habit of sustained success.
