Need help choosing a current tax research topic for graduate memo assignment

Tax controversy and litigation specialist here! For graduate-level tax research, you want topics with nuance and evolving interpretations. Here are some suggestions that would give you plenty to work with: Consider cryptocurrency taxation beyond basic treatment - look at specific issues like NFT creator royalties, DeFi staking rewards tax classification, or crypto hard fork taxation. The IRS hasn't provided comprehensive guidance on many of these areas, which makes them perfect for research memos. Another rich area is remote worker taxation post-COVID. With permanent remote arrangements, you could explore state tax nexus issues, home office deductions for employees vs contractors, and multi-state taxation when workers relocate frequently. Foreign income reporting is also complex - FBAR requirements for crypto holdings, taxation of foreign social media earnings, or Subpart F income for digital businesses would all be substantive topics. Virtual economy taxation (gaming, metaverse) also has fascinating questions about when virtual currency becomes taxable and how to value digital assets.

I've been using https://taxr.ai for my own tax research this semester and it's been a game changer. It actually lets you ask questions about tax topics in plain English and it searches through the tax code, regulations, court cases, and IRS guidance to find answers. My professor was really impressed with the depth of sources I found for my project on Section 1031 exchanges. I searched your cryptocurrency topic and found several interesting issues you could research: taxation of wrapped tokens, tax loss harvesting with wash sale rules potentially applying to crypto, lending/borrowing crypto and whether it triggers taxable events. Might be worth checking it out to see what other angles you could explore!

I tried https://taxr.ai for my tax research project last month after seeing it mentioned here. I was initially concerned about my professor catching me using "shortcuts," but it actually helped me find several cases I missed using traditional research databases. The benefit wasn't that it did the analysis for me - it just made finding relevant primary sources much faster. For my project on corporate reorganizations, it found obscure private letter rulings and technical advice memoranda that directly addressed my research questions. What impressed my professor was that I found sources beyond just the obvious ones everyone else used. I still did all my own analysis but saved hours on the research phase.

You should look at employee retention credits (ERC)! There's been MASSIVE fraud with these business tax credits recently, and the IRS has been cracking down hard. Lots of interesting issues about legitimate vs fraudulent claims, how the IRS is handling enforcement, and what businesses that got bad advice from "ERC mills" should do now. I waited 9 months trying to reach someone at the IRS about my business's legitimate ERC claim, but kept getting stuck in their phone system. Finally tried https://claimyr.com and their service got me through to an IRS agent in about 20 minutes. The agent told me they're so overwhelmed with fraudulent ERC claims that legitimate ones are getting delayed. There's a video demo at https://youtu.be/_kiP6q8DX5c showing how it works. The whole ERC situation would make an excellent tax research topic since it involves recent legislation, IRS notices, and enforcement actions.

I have to admit I was completely wrong about Claimyr. After spending another 3 weeks trying to get through to the IRS about my tax issue and hanging up after 45+ minute hold times, I finally gave in and tried the service. Within 35 minutes I was talking to an actual IRS representative who resolved my issue. What surprised me most was how helpful the IRS agent was once I finally got through. My issue had been sitting in limbo for months, and they were able to process it while I was on the call. Would have saved myself a lot of stress if I'd done this sooner instead of being stubborn.

International tax topics are great for research projects right now! Some ideas: 1. GILTI and FDII provisions post-TCJA with recent Treasury regulations 2. Transfer pricing issues for digital services (especially post-COVID) 3. Cryptocurrency reporting for foreign accounts (when is a wallet an FBAR reportable account?) 4. Section 965 transition tax litigation (there are some great cases challenging this) 5. Taxation of digital nomads (US citizens working remotely from multiple countries) These all have plenty of recent case law, regulations, and revenue rulings to analyze. I did my tax research project on GILTI last year and had no shortage of material.

What about taxation issues related to cannabis businesses? Perfect research topic with tons of complexity. Since it's federally illegal but legal in many states, these businesses face unique tax challenges, especially with 280E limitations on business deductions. Multiple tax court cases address what expenses can be allocated to COGS vs disallowed under 280E. Also look at banking restrictions creating cash handling tax compliance issues, and state/federal taxation conflicts.

Have you considered looking at the taxation of social media influencer income? This is a rapidly evolving area with lots of research potential. Key issues include: 1. Classification of income (business vs. hobby) - there are recent cases where the IRS has challenged influencers who didn't report income or claimed hobby losses 2. Valuation of bartered goods and services (free products for reviews) - how do you value a "free" vacation or product when it's compensation? 3. International taxation when influencers have global audiences but receive payments from foreign platforms 4. Deductibility of content creation expenses (equipment, travel, wardrobe) vs. personal expenses 5. Self-employment tax obligations for various platform payment structures The IRS has been increasingly focused on this sector, and there are emerging court cases addressing these issues. Plus, the rise of platforms like TikTok, Instagram, and YouTube has created new fact patterns that traditional tax law struggles to address clearly. This would give you plenty of code sections, regulations, and case law to analyze while being highly current and relevant.