In this joint episode with the Personal Financial Planning (PFP) Section podcast, host Cary Sinnett discusses recent IRS communications around certain exchange-traded fund (ETF)- based diversification strategies with Robert Keebler, CPA/PFS, MST, AEP (Distinguished), CGMA.

Sec. 351 ETF contributions may be permissible, but rapid redemptions for diversified securities may be taxable under the step-transaction doctrine. Timing, prearranged plans, marketing and communications are key.

Practitioners should review completed and pending transactions, documentation, reporting, disclosure, privilege, and penalty protection, coordinating with investment advisers and tax counsel as appropriate.

Questions answered in this episode:

• What is a Sec. 351 ETF strategy, and why is the IRS scrutinizing it?
• When could the strategy become taxable under the step-transaction doctrine?
• Which factors distinguish legitimate planning from a prearranged taxable exchange?
• What should advisors and clients do about pending or completed transactions?

AICPA resources

Section 351 Resource

IRS resources

IRS Notice 2026-62

Revenue Ruling 2026-20

Keep your finger on the pulse of the dynamic and evolving tax landscape with insights from tax thought leaders in the AICPA Tax Section. The Tax Section Odyssey podcast includes a digest of tax developments, trending issues and practice management tips that you need to be aware of to elevate your professional development and your firm practices.

This resource is part of the robust tax resource library available from the AICPA Tax Section. The Tax Section is your go-to home base for staying up to date on the latest tax developments and providing the edge you need for upskilling your professional development. If you're not already a member, consider joining this prestigious community of your tax peers. You'll get free CPE, access to rich technical content such as our Annual Tax Compliance Kit, a weekly member newsletter and a digital subscription to The Tax Adviser.

Filing season risk starts well before the first return is prepared. In this episode, April Walker talks with Sarah Ference, CPA, Risk Control Director at CNA, about how thoughtful client selection, clear engagement letters and proactive communication can help firms set expectations, manage scope creep and reduce risk. Learn practical steps you can take now to build stronger client relationships — and a smoother filing season.

• Why should engagement letters be viewed as client relationship tools — not simply legal documents?
• How can firms clearly define the scope of tax services and prevent "one quick question" from becoming scope creep
• When and how should practitioners document informal advice and client conversations?
• What factors should firms consider when deciding whether to retain, rehabilitate or disengage from a client?
• What practical steps can firms take now to reduce risk and prepare for a smoother filing season?

AICPA resources

Reimagining Your Tax Practice

Annual Tax Compliance Kit

Private Companies Practice Section (PCPS) homepage

Keep your finger on the pulse of the dynamic and evolving tax landscape with insights from tax thought leaders in the AICPA Tax Section. The Tax Section Odyssey podcast includes a digest of tax developments, trending issues and practice management tips that you need to be aware of to elevate your professional development and your firm practices.

This resource is part of the robust tax resource library available from the AICPA Tax Section. The Tax Section is your go-to home base for staying up to date on the latest tax developments and providing the edge you need for upskilling your professional development. If you're not already a member, consider joining this prestigious community of your tax peers. You'll get free CPE, access to rich technical content such as our Annual Tax Compliance Kit, a weekly member newsletter and a digital subscription to The Tax Adviser.

Economist Dr. Anirban Basu, founder of Sage Policy Group and keynote speaker at the National Tax Conference (NTC) joins Neil Amato, host of the Journal of Accountancy (JofA) podcast, for a wide-ranging conversation about the forces shaping today's economy and what they could mean for tax practitioners and their clients. From inflation, interest rates and the labor market to artificial intelligence (AI) and the nation's fiscal challenges, Dr. Basu offers perspective on navigating an economy where the headlines don't always tell the whole story.

Questions answered in this episode:

• What economic trends should tax practitioners be watching right now?
• How do economic conditions affect tax practitioners and their clients?
• Why is the economy difficult to characterize as simply either "good" or "bad?"
• How is AI changing professional work and where does human judgement still matter?
• What could today's national debt and fiscal challenges mean for the tax system in the years ahead?

Join us live or online at the 2026 NTC and hear Dr. Basu deliver his keynote titled First Brood.

Keep your finger on the pulse of the dynamic and evolving tax landscape with insights from tax thought leaders in the AICPA Tax Section. The Tax Section Odyssey podcast includes a digest of tax developments, trending issues and practice management tips that you need to be aware of to elevate your professional development and your firm practices.