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Foodman CPAs & Advisors

IRS Use of AI Can Close Tax GAP

On 10/12/23, the IRS announced new tax gap projections for tax years 2020 and 2021 showing the projected gross tax gap increased to $688 billion in tax year 2021, a rise of more than $192 billion from the prior estimates for...more

Foodman CPAs & Advisors

Taxpayers Abroad are Underserved and Challenged

The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more

Blank Rome LLP

To Be or Not To Be A Unitary Business

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Oftentimes companies are on the defense in establishing that they are not operating a unitary business to avoid excessive taxation by a State. Yet, there are occasions when companies take the offense—and are successful. In...more

Bowditch & Dewey

Spousal Relief From Joint Tax Liability

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As a general rule, when a married couple files a joint tax return, they are jointly and severally liable for the entire tax. But what happens if one spouse failed to report income and the other spouse did not know or have...more

Gray Reed

IRS Continues Focus On Large Partnerships: 3 Items To Watch Out For

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In recent years, the IRS has focused its attention and resources on large partnerships. In 2021, the agency launched an initial phase of its Large Partnership Compliance (LPC) program. Under this program, the IRS identified...more

Holland & Knight LLP

Tax Court: IRS Must Adhere to BBA Regulations' Plain Language

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The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more

Kilpatrick

Around the Country: Recent Cases in Tax Penalty Abatement

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Introduction – What Is Tax Penalty Abatement? Audits can be an incredibly frustrating ordeal. From initial contact with tax authorities to digging up old financial records to possibly increasing tax liability, there are...more

Cadwalader, Wickersham & Taft LLP

Crypto: Give Unto Caesar What Is Caesar’s

Earlier this year the U.S. Department of Justice (“DOJ”) brought USA v. Ahlgren, its first crypto case with tax evasion allegations unrelated to another crime, demonstrating the DOJ’s willingness to pursue stand-alone crypto...more

Foodman CPAs & Advisors

Estrategias Y Esquemas Tributarios Para Evitar Impuestos A La Vanguardia Del IRS

El 11/04/24, el IRS concluyó su Lista de la Docena Sucia de 2024 con una “advertencia a los contribuyentes sobre los promotores que venden estrategias fiscales falsas y esquemas extraterritoriales fraudulentos diseñados para...more

Foodman CPAs & Advisors

Tax Strategies And Schemes To Avoid Taxes At IRS Forefront

On 4/11/24, the IRS wrapped up its 2024 Dirty Dozen List with a “warning to taxpayers regarding promoters selling bogus tax strategies and fraudulent offshore schemes designed to reduce or avoid taxes altogether”. Tax...more

Locke Lord LLP

In Innocent Spouse Tax Cases, How You Tell Your Story Matters

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Married people who file their taxes jointly typically choose this option because of its tax advantages. But when a spouse commits a misdeed, you’re still jointly and severally responsible for the payment of taxes. ...more

Bowditch & Dewey

I Made a Mistake on My Taxes – Now What Do I Do?

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Mistakes happen, and the tax law can be complex and ambiguous. The question becomes, what does a taxpayer do if they discover a mistake on their tax return? Should an amended tax return be filed? In some cases, the taxpayer...more

McDermott Will & Emery

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

Rivkin Radler LLP

IRS Cannot Offset Taxpayer’s Refund With A Disputed Tax Liability

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Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more

Blank Rome LLP

Understanding Residency and Domicile in Determining State Income Taxation

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State income taxes play a prominent role in overall tax planning for individuals. A change of residence/domicile from a higher-tax state to a lower- (or no-) tax state is often considered when contemplating retirement or the...more

Kelley Drye & Warren LLP

Opportunities Exist to Challenge Taxpayers’ Penalty Assessments for Failure to Report Large Foreign Gifts

U.S. citizens and residents who have received gifts (including bequests) exceeding certain thresholds from foreign persons must generally report such gifts to the IRS. Recipients of such gifts who do not report them in a...more

Foodman CPAs & Advisors

Todas Las Fuentes De Ingresos Deben Reportarse En La Declaración De Impuestos

El 3/6/24, el IRS publicó un recordatorio a todos los contribuyentes de que todas las fuentes de ingresos deben declararse en su declaración de impuestos. El IRS está prestando mucha atención a todas las fuentes de ingresos...more

Foodman CPAs & Advisors

All Sources Of Income Must Be Reported On Tax Return

On 3/6/24, the IRS released a reminder to all taxpayers that all sources of income must be reported on their tax return. The IRS is paying close attention to all sources of income derived from digital asset transactions, the...more

Vedder Price

IRS Targets High-Income Non-Filers

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High-income non-filers are being contacted by the Internal Revenue Service (“IRS”) about their tax noncompliance. The IRS announced on February 29, 2024 a new enforcement campaign focused on taxpayers at the high-end of the...more

Ballard Spahr LLP

Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent...

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In this episode, we are joined by Special Agent Jonathan Schnatz, Senior Analyst with IRS Criminal Investigation. Special Agent Schnatz will discuss his work with an international law enforcement and tax compliance group, and...more

Fox Rothschild LLP

IRS to Focus on High-Income Earners Who Have Not Filed Tax Returns Since 2017

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The IRS expects to send out over 125,000 collection letters to high-income taxpayers who did not file one or more federal income tax returns between 2017 and 2021. As part of the new collection initiative, approximately...more

Bowditch & Dewey

Update Your 2024 Tax Withholding to Avoid Year-End Surprises

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Now that the 2023 tax filing season is underway, many taxpayers are having an unpleasant surprise when they file their tax return this year and find out they are getting a much smaller refund than they were expecting, or...more

Allen Barron, Inc.

What Does the Recent OTA Ruling Tell You About a California Tax Audit?

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What does the recent OTA ruling tell you about a California tax audit? What can we learn from the results of an investigation by the Office of Tax Appeals (OTA) into the practices of a California tax agency? Why do you need...more

Bowditch & Dewey

Recently Married – Should We File a Joint Tax Return?

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After the excitement of the wedding and honeymoon is over, newlyweds should start thinking about joint finances and their income taxes. A common question for those recently married is whether or not to file a joint tax...more

Foodman CPAs & Advisors

Avisos De Cobros Del IRS Se Reiniciarán En 2024

Avisos de Cobros del IRS se reiniciarán en 2024 así como un nuevo alivio de multas para aproximadamente 4.7 millones de personas, empresas y organizaciones exentas de impuestos a las que no se les envió un recordatorio...more

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