Let’s Talk About Tax

Commercial property taxpayers had an eventful year at the Minnesota Tax Court, which handed down several taxpayer wins but also several notable losses. As we reach the end of 2025, we take a moment to look back on some of this year’s biggest valuation decisions in the commercial property tax space.

On November 5, 2025, the U.S. government shutdown became the longest in history. The shutdown has disrupted many Americans’ businesses, benefits and travel plans. But little attention has been given to the shutdown’s effects on taxpayers and the operation of and administration by the IRS.

The One Big Beautiful Bill Act has enacted many fundamental tax policy changes. One of those changes that may be flying under the radar is the change in itemized charitable deductions. Starting in 2026, OBBBA introduces significant changes to charitable deduction rules for both individuals and estates and trusts, thus adding complexity for taxpayers and advisors.

The Treasury Department and IRS have released Notice 2025-42, overhauling the rules for determining the Beginning of Construction (BOC) of a project for purposes of the §45Y production tax credit and §48E investment tax credit as it applies to wind and solar facilities. 

Since the passage of the Inflation Reduction Act in August 2022, the U.S. Department of the Treasury and the IRS have issued seemingly nonstop guidance. Even with the Supreme Court’s recent reversal of the Chevron deference principle, Treasury and the IRS continue their work. The two federal agencies have gone to great lengths to listen, respond, and even occasionally adopt public comments.

On June 28, in a 6-3 decision along ideological lines, the U.S. Supreme Court—in Loper Bright Enterprises v. Raimondo—overturned a seminal 1984 administrative law case, Chevron U.S.A. Inc. v. Natural Resources Defense Council.

On Thursday, June 20, 2024, the Supreme Court handed down its long-awaited tax decision in Moore v. U.S. And, an interesting set of opinions it is (all 83 pages of them)!

On June 6, 2024, the U.S. Supreme Court unanimously held that, for federal estate tax purposes, a company’s obligation to redeem shares from a deceased shareholder’s estate does not offset life insurance proceeds used by the company to satisfy that obligation.

The new "economic reality" test issued by the U.S. Department of Labor provides additional clarity and important worker protections, but it went into effect quickly—on March 11, 2024—leaving employers scrambling to ensure that their workers are properly classified.

The U.S. Supreme Court will hear another tax case in the upcoming 2023-2024 session. This one, Moore v. United States, is a doozy...