Tax Notes Talk Year-End Collection: Tax Oddities of 2025
Dec 24, 2025
Trevor Sykes, a Tax Notes legal reporter, dives into the intriguing exclusion of tips for pornographic activities and the complexities of platforms like OnlyFans. Nathan Richman discusses the intense legal saga around Ian Freeman's crypto church tax convictions, highlighting the court's stance on willfulness. Amanda Athanasiu explores the implications of marital discord in FBAR cases, illustrating that hiding accounts from a spouse isn't an acceptable excuse. Emily Hollingsworth reports on Hasbro's significant tax credits tied to their move to Boston, revealing state tax strategy dynamics.
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Undefined Pornography Exclusion Creates Legal Uncertainty
- Proposed regs exclude tips from illegal activities and "pornographic activities," but the regs give no definition of pornography.
- Trevor Sykes highlights the legal and First Amendment uncertainty this creates for tax administration.
Digital Creators Caught In The Crosshairs
- The pornographic-activity exclusion mainly affects digital content creators who receive tips on platforms like OnlyFans.
- Trevor Sykes notes millions of creators and large subscriber payments make this a significant taxpayer group.
SSTB Rules Overlap With Tip Deduction Limits
- OB-3 allows a $25,000 deduction for qualified tipped income but disqualifies tips tied to SSTBs.
- Trevor Sykes explains SSTB rules may already bar many adult-content creators regardless of the pornographic carve-out.