Tax Brief2026 SALT deduction limits and W-2 Box 14 changes
Prepare for 2026 with increased SALT deduction limits, a new split for Form W-2 Box 14 reporting, and updated health plan transparency rules.
The Tax Court held the 90-day BBA petition deadline is not jurisdictional, and the IRS granted Section 1362(f) relief for a late ESBT election.
01. BBA audit deadline not jurisdictional
- The Tax Court held that the 90-day deadline under IRC Section 6234(a) to file a petition following a BBA Final Partnership Adjustment is not a jurisdictional bar.
- Because the 90-day BBA petition deadline is nonjurisdictional, late-filed petitions are not automatically dismissed and may potentially qualify for equitable tolling.
Source: US Tax Court Opinions · 2026-08-05
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02. S-corp inadvertent termination relief
- The IRS granted Section 1362(f) inadvertent termination relief to an S corporation after a shareholder trust failed to timely file an Electing Small Business Trust (ESBT) election.
- To maintain S corporation status, the taxpayer was given 120 days from the date of the ruling to file the late ESBT election and any necessary amended tax returns.
Source: IRS Written Determinations · 2026-08-07
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Written by Iris
Published on August 10, 2026