Samuel F. Hamer
Subscribe to Samuel F. Hamer's PostsSamuel (Sam) F. Hamer focuses his practice on US and international tax matters. Read Sam Hamer's full bio.
Major update: Potential refund opportunity for interest and penalty amounts accrued during COVID-19 federally declared disaster
By Shawn O’Brien and Samuel F. Hamer on Dec 8, 2025
Posted In Court Procedure Matters, IRS Appeals, IRS Audits, Penalties, Settlements, Significant Court Decision, Tax Refunds
The US Court of Federal Claims’ (CFC) recent decision in Kwong v. United States, No. 23-267 (Fed. Cl. Nov. 25, 2025), provides significant support for the potential refund opportunity we identified in a previous blog post titled, “Refund opportunity for interest and penalty amounts accrued during COVID-19 federally declared disaster.” The refund opportunity applies to...
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IRS roundup: November 7 – November 24, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney on Dec 2, 2025
Posted In Court Procedure Matters, IRS Guidance, Significant Court Decision, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for November 7, 2025 – November 24, 2025. November 10, 2025: The IRS released Internal Revenue Bulletin No. 2025-46, which includes proposed regulations 109742-25. The proposed regulations would remove a rule in previous final regulations that uses the shareholders of...
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Tax consulting firm permitted to challenge final micro-captive reporting regulations
By Samuel F. Hamer on Dec 2, 2025
Posted In Court Procedure Matters, Significant Court Decision, Trial Courts
Ryan, LLC v. Internal Revenue Service[1] is the latest example of success in overcoming procedural hurdles to challenge the validity of a US Department of the Treasury (Treasury) regulation. In a recent opinion, the US District Court for the Northern District of Texas held that: Ryan has standing to challenge the validity of the Treasury’s...
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IRS roundup: October 23 – November 6, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney on Nov 7, 2025
Posted In IRS Guidance, Penalties, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for October 23, 2025 – November 6, 2025. October 23, 2025: The IRS issued frequently asked questions, addressing its revisions and updates to Form 1099-K following changes resulting from the One Big Beautiful Bill Act (OBBBA). The OBBBA retroactively reinstated...
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IRS roundup: October 7 – October 23, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney on Oct 28, 2025
Posted In IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for October 7, 2025 – October 23, 2025. October 7, 2025: The IRS issued Notice 2025-55, providing guidance on relief from failure to deposit penalties under Internal Revenue Code (Code) Section 6656 as it relates to a new excise tax...
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IRS roundup: September 19 – October 1, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney on Oct 8, 2025
Posted In Appellate Courts, Court Procedure Matters, IRS Guidance, Tax Reform, Transfer Pricing Resource
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for September 19, 2025 – October 1, 2025. September 19, 2025: The US Department of the Treasury (Treasury) and the IRS issued proposed regulations, providing guidance on the “no tax on tips” provision of the One Big Beautiful Bill Act....
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IRS roundup: August 28 – September 15, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney on Sep 18, 2025
Posted In Appellate Courts, Court Procedure Matters, IRS Guidance, Tax Reform, Transfer Pricing Resource
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for August 28, 2025 – September 15, 2025. August 28, 2025: The IRS issued Revenue Procedure 2025-28, providing guidance on making certain elections for domestic research or experimental expenditures under § 70302(f) of the One Big Beautiful Bill Act (OBBBA). Revenue...
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IRS roundup: August 12 – August 20, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney on Aug 27, 2025
Posted In IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for August 12, 2025 – August 20, 2025. IRS guidance August 15, 2025: The IRS issued Notice 2025-42, providing guidance consistent with Executive Order 14315, Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled Energy. This notice specifically provided guidance on when...
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IRS roundup: July 12 – July 29, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney on Aug 15, 2025
Posted In IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for July 12, 2025 – July 29, 2025. IRS guidance July 15, 2025: The IRS issued Revenue Ruling 2025-14, providing prescribed rates for federal income tax purposes for August 2025, including but not limited to: Short-, mid-, and long-term applicable...
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IRS roundup: June 18 – July 11, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney on Jul 15, 2025
Posted In IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for June 18, 2025 – July 11, 2025. “One Big Beautiful Bill Act” tax provisions On July 4, 2025, US President Donald Trump signed the “One Big Beautiful Bill Act” (OBBBA) into law, which enacted several changes to federal tax...
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