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The IRS has released the June 2026 revisions to Forms 433-A (Collection Information Statement for Wage Earners and Self-Employed Individuals) and 433-B (Collection Information Statement for Businesses), introducing several noteworthy changes that practitioners should be aware of immediately. 

These updates reflect a continued shift toward more detailed financial disclosures and enhanced data collection during IRS collection reviews.

Key Changes to Form 433-A (June 2026 Revision)

The revised Form 433-A includes several structural and substantive updates designed to expand the scope of financial and personal information collected:

·         Expanded dependent reporting: The form now accommodates up to five dependents directly on the main form, an increase from three under the July 2022 version. A supplementary schedule is only required when a taxpayer has six or more dependents.

·         New income fluctuation disclosure: Taxpayers must now indicate whether they anticipate any increase or decrease in income. If yes, the form requires disclosure of the expected timing, projected amount, and a brief explanation. This change signals a more forward-looking approach by the IRS in evaluating collection potential.

·         Passport and citizenship questions: Two new questions have been added:

o    Whether the taxpayer holds a United States passport

o    Whether the taxpayer has dual citizenship

·         Although the IRS has not formally explained the addition, these questions likely tie into enforcement considerations such as passport certification under IRC § 7345, evaluation of foreign ties, and identification of potential offshore assets.

·         Expanded asset reporting capacity: The updated form allows more entries directly within the main document, reducing the need for attachments:

o    Up to four bank accounts

o    Up to four investment accounts

o    Up to four digital asset holdings

o    Up to four credit cards

o    Up to three real properties

o    Up to three personal vehicles

·         Enhanced real property disclosures: The IRS now requires identification of all title holders for each property, in addition to specifying how title is held (e.g., joint tenancy, tenancy by the entirety). This aligns with increased scrutiny of ownership structures and equitable interests.

·         Business asset ownership transparency: A new field requires disclosure of all title holders of business assets, further reinforcing the IRS’s focus on beneficial ownership and asset tracing.

Key Changes to Form 433-B (June 2026 Revision)

The primary update to Form 433-B is the formal separation of digital assets into their own reporting category. Previously reported under investments, digHim him himtal assets now receive dedicated treatment, underscoring the IRS’s continued focus on cryptocurrency and other blockchain-based holdings in collection matters.

Updated Client Questionnaires

To align with these revisions, both the individual and business client questionnaires, which we use, have been updated to capture all newly required information. Practitioners should ensure that intake processes are revised accordingly to avoid delays or incomplete submissions.

Practice Considerations

These changes collectively suggest a broader IRS initiative to enhance visibility into a taxpayer’s current and future financial condition, as well as their potential access to offshore or hard-to-trace assets. The addition of forward-looking income questions and citizenship disclosures may become particularly relevant in cases involving:

·         Installment agreement negotiations

·         Offers in compromise

·         Currently not collectible determinations

·         Cases involving international exposure or dual residency

Practitioners should also be mindful of how these disclosures could influence enforcement actions, including passport restrictions and cross-border collection strategies.

·         If an older version of the form appears in your browser, perform a hard refresh (Ctrl + F5) or clear your cache to ensure you are accessing the updated version.

·         The IRS has also updated its Collection Financial Standards. If timing permits, consider delaying submission of a Collection Information Statement until the revised standards are fully incorporated into your analysis, as they may impact allowable expense calculations and overall resolution strategy.

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Read more at: Tax Times blog

The U.S. Supreme Court recently declined to hear a closely watched case that could have reshaped how tax penalties are litigated, particularly with respect to jury trial rights. The decision leaves intact existing procedural norms in tax controversy—at least for now.

Background of the Case

The dispute arose from IRS fraud penalties exceeding $30 million assessed against two couples, the Hirsches and the Birdmans, tied to alleged misreporting and improper claims of U.S. Virgin Islands residency between 2003 and 2006. The taxpayers challenged the penalties in U.S. Tax Court and requested jury trials, arguing that the penalties were punitive in nature and therefore triggered Seventh Amendment protections.

The Tax Court rejected that request, reiterating the longstanding position that taxpayers do not have a constitutional right to a jury trial in deficiency proceedings against the federal government.

The Jarkesy Argument

The taxpayers’ position gained momentum following the Supreme Court’s 2024 decision in SEC v. Jarkesy, where the Court held that the SEC violated the Seventh Amendment by imposing civil penalties through administrative proceedings without a jury. Relying on that precedent, the taxpayers argued that IRS fraud penalties are similarly punitive and should entitle them to a jury trial.

They sought a writ of mandamus from the Eleventh Circuit to compel the Tax Court to grant a jury trial, asserting that Jarkesy effectively invalidates juryless adjudication of such penalties.

Eleventh Circuit and Mandamus Standard

The Eleventh Circuit denied the request, applying the traditional mandamus standard. The court found that:

·         The taxpayers had alternative means of relief, including appealing a final Tax Court decision.

·         Their right to a jury trial was not “clear and indisputable.”

The taxpayers argued this approach conflicts with other circuits and deepens an existing split over how mandamus should be applied in the jury trial context.

Supreme Court Declines Review

On June 22, 2026, the Supreme Court denied certiorari without comment. While not a ruling on the merits, the denial effectively preserves the status quo:

·         Tax Court proceedings remain non-jury forums.

·         Taxpayers cannot use mandamus as a shortcut to secure jury trials in pending tax cases.

·         The broader constitutional question post-Jarkesy remains unresolved.

Practical Implications

For tax practitioners, the decision reinforces several key points:

·         Jury trials in federal tax disputes remain limited to refund litigation in district court or the Court of Federal Claims—not Tax Court deficiency cases.

·         Jarkesy has not (yet) been extended to IRS enforcement or civil tax penalties.

·         Procedural challenges to Tax Court jurisdiction or structure will likely need to proceed through full litigation and appeal rather than interlocutory relief.

Looking Ahead

Although the Supreme Court declined to take up this case, the underlying issue is far from settled. With continued litigation and support from advocacy groups, the question of whether certain tax penalties are sufficiently punitive to trigger Seventh Amendment protections may return to the Court in a future case with a cleaner procedural posture.

 Do You Have Undeclared Offshore Income?

Read more at: Tax Times blog

According to Laws360, Ireland's payments to the U.S. for intellectual property showed a dramatic increase between 2020 and 2026, indicating that IP development returned to the U.S. after the implementation of the 2017 Tax Cuts and Jobs Act, the head of a Washington-based think tank said.

Daniel Bunn, president and CEO of the Tax Foundation, presented a chart to those attending a tax conference hosted by the United States Council for International Business in Washington, D.C., that showed IP payments from Ireland to the U.S. between 2008 and 2026. Those payments, according to the illustration, were well below €10 trillion ($11.4 trillion) between 2008 and 2019 and then jumped to over €40 trillion by 2026.

The information, Bunn said, shows the effect of both the 2017 tax act, which, among other changes, lowered the top U.S. corporate tax rate to 21% from 35%  and the elimination of a popular tax planning strategy known as the double Irish Dutch sandwich. The structure, whereby European sales were routed through a head office with no employees or physical presence, was used by many large U.S. technology companies to avoid withholding taxes in Europe.

O'Reilly, deputy head of the OECD's tax policy and statistics division and head of its business and international taxes unit, addressed the impact of the global minimum tax, for which the first returns from companies are due at the end of the month. At this point, he said, it is too early to assess how well the regime is working.

Nearly 140 countries agreed to the 15% minimum tax, known as Pillar Two, in 2021, and a deal reached in January exempts the U.S. from the provision with the understanding that it imposes its own minimum tax requirements. The January agreement recognized that the U.S. tax regime — and potentially others — could operate "side by side" with Pillar Two.

O'Reilly said "Let's wait and see whether the rule … that we are now putting into place or happened in the last couple of years is really working," he said. "It's not time yet, because we have not yet seen the full effects of the rules that are in place."

Need Tax Advice ?

     Contact the Tax Lawyers at

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
or Toll Free at 888 8TAXAID (888-882-9243)

Read more at: Tax Times blog

According to Henley Private Wealth Migration Report 2026, 2026 is shaping up to be a record-breaking year for millionaire migration internationally. The latest edition of this annual report introduces the Global Wealth Mobility Framework, revealing how tax, policy, geopolitics, and international access are reshaping the competition to attract millionaires on the move.

According to the report, Singapore, Italy, Switzerland, Greece, Hong Kong, and New Zealand are emerging as some of the most attractive destinations for internationally mobile wealth in 2026, while the United Kingdom, Germany, France, Norway, and South Korea are facing growing competitiveness pressures as tax reforms, fiscal uncertainty, and policy shifts prompt wealthy individuals and families to reassess their options.

Millionaire migration is more than a trend—it’s a barometer of global confidence, policy effectiveness, and the shifting sands of economic opportunity. The fastest-growing wealth markets are often those that attract migrating millionaires or are emerging tech hubs, highlighting the crucial role of mobility in wealth creation.

As 2026 unfolds, the global map of wealth is being redrawn, one millionaire at a time.

According to CNBC the top reason why Americans abroad want to dump their U.S. citizenship include:

• Nearly 1 in 4 American expatriates say they are “seriously considering” or “planning” to ditch their U.S. citizenship, a survey from Greenback Expat Tax Services finds.  
• About 9 million U.S. citizens are living abroad, the U.S. Department of State estimates.
• More than 4 in 10 who would renounce citizenship say it’s due to the burden of filing U.S. taxes, the Greenback poll shows.

Should I Stay or Should I Go?

Need Advise on Expatriation?

 

Contact the Tax Lawyers at 

Marini & Associates, P.A.   

for a FREE Tax Consultation contact us at:

www.TaxAid.com or www.OVDPLaw.com 
or Toll Free at 888-8TaxAid (888) 882-9243

Read more at: Tax Times blog