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Tax Returns

Tax Payment Plans: What Do You Do? (Part 3)

by McNair Law Firm, P.A. on

If an individual or business owes federal taxes and does not have the current ability to pay these taxes, the IRS can “seller-finance” and offer a payment plan with the taxpayer. The primary benefit of a payment plan is that...more

New partnership audit rules can apply to partnerships, LLCs with only a few partners, members

by Thompson Coburn LLP on

Effective in 2018, changes in partnership audit rules may apply the following (and other) consequences to partnerships (including LLCs taxed as such)...more

When A Partner May Not Be Acting As A Partner

by Farrell Fritz, P.C. on

It is not uncommon for a partner to engage in a business transaction with a partnership of which he is a member. If the partner engages in a transaction with his partnership other than in his capacity as a partner, he will be...more

IRS Tax Penalties

by Dickinson Wright on

In a famous saying by Benjamin Franklin, “… but in this world nothing can be said to be certain, except death and taxes.” In the past 100 years, it would be very safe to add to the end of that quote, “and the Internal...more

Unfiled Tax Returns: What Do You Do? (Part 2)

by McNair Law Firm, P.A. on

The United States has a voluntary income tax reporting system. U.S. citizens, permanent residents, and businesses here must annually file income tax returns with the IRS, reporting their “worldwide income”, deductions, and...more

Are you a Taxpayer identified by IRS for not Reporting Offshore Financial Assets?

by Foodman CPAs & Advisors on

Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful. The definition of “Willful" or "non-willful” in Taxpayer’s conduct...more

You Owe IRS Taxes: What Do You Do? (Part 1)

by McNair Law Firm, P.A. on

Many individuals and businesses owe taxes to the IRS, or they have not filed their tax returns or both. While the IRS may be the most powerful creditor in the world, there are solutions. This is Part I of a series addressing...more

Return to Windsor: A Novel Tax Code Correction

by Lewitt Hackman on

Here’s the next chapter in the saga known as Edith Schlain Windsor v. The United States of America. (For a quick recap, please read Tax & Estate Planning – Small Win for Same Sex Couples?). Two representatives of the state...more

Here is what you need to know about a Domestic Voluntary Disclosure (DVD)

by Foodman CPAs & Advisors on

DVD can be an option for a Taxpayer without foreign financial accounts or foreign financial issues. It is a choice for Taxpayers that are out of domestic compliance, want to come into compliance and inoculate as much as...more

ALJ Forces Combination of Hedge Fund Group in New York City - Tax Update Volume 2017, Issue 4

by Pepper Hamilton LLP on

On April 27, the New York City Tax Appeals Tribunal issued a decision requiring the related members of a hedge fund group to file a combined return for New York City tax purposes. However, the administrative law judge (ALJ)...more

Related-Party Provisions Prevent Deduction by S Corp Shareholders - Tax Update Volume 2017, Issue 4

by Pepper Hamilton LLP on

Many routine transactions occur between related parties, including the payment or accrual of interest on indebtedness, license fees, salary or benefits to employees and/or shareholders, and trade invoices. The Tax Court...more

Federal Tax Treatment of Employer-Provided Identity Protection Services

In the wake of several recent high-profile security breaches, employers are increasingly viewing identity theft protection as an essential employee benefit for employees. According to Willis Towers Watson’s 2016 voluntary...more

IRS Grants Taxpayers Two-Year Window to File Portability Election

by Bryan Cave on

In a long-awaited move, the IRS announced recently that taxpayers will now have at least two years to file an estate tax return to elect portability of a decedent’s unused estate tax exemption to the decedent’s surviving...more

Stolen Tax Returns? Virginia Seeks a Solution.

Did someone steal your tax return? You are not alone. Indeed, the rise in tax-related identity theft has been well documented. In 2015, the FTC reported a 50% increase in identity theft complaints. A primary cause for...more

Size Protest Update: Can The SBA Rely On Tax Returns Filed After The Date Of Self-Certification?

by Fox Rothschild LLP on

The baseline rule for SBA size protests is that a business’s size (for a receipts-based size standard) is determined by looking at the average annual receipts for the last three completed fiscal years. But what if a...more

IRS Schools Taxpayers On Duty Of Consistency

by Charles (Chuck) Rubin on

Shirley died in October 1997. The estate filed an estate tax return and paid the tax indicated. The IRS subsequently audited Shirley’s estate and issued a notice of deficiency. After Tax Court proceedings, the court issued a...more

FBAR Penalties Now Adjusted for Inflation: Abatement/Mitigation Still Possible

If you haven’t filed your Report of Foreign Bank and Financial Accounts (FBARs) on a timely basis, you could be at risk of a higher civil penalty assessment. Inflation-adjusted FBAR penalties are now in effect....more

Tax-Exempt Does Not Mean Exempt From Filing Tax Returns

May 15 was the filing deadline for nonprofits operating on a calendar year that are required to file Form 990-series information returns. Many nonprofits mistakenly believe that they are not required to file returns with the...more

IRS Reminds U.S. Taxpayers Living Abroad of Misc. Filing Due Dates and Filings

by Charles (Chuck) Rubin on

In News Release 2017-105, the IRS reminded U.S. taxpayers living abroad: The extended due date, if the taxpayer had his or her tax home and abode abroad on the original due date, is June 15. But interest on taxes runs from...more

Proposed Partnership Audit Regulations Reissued in Substantially Identical Form

by Proskauer - Tax Talks on

On June 13, 2017, the U.S. Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) re-released proposed regulations (REG 136118-15) that provide guidance on the new centralized partnership audit...more

IRS Simplifies Ability To Obtain Late Portability Election Relief

by Cole Schotz on

On June 9, 2017, the Internal Revenue Service issued Revenue Procedure 2017-34, which is effective immediately and provides a simplified method to obtain permission for an extension of time under Reg. 301.9100-3 to file Form...more

This Week in FCPA-Episode 56

by Thomas Fox on

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. The Kokesh case at the US Supreme Court is significant for SEC enforcement of the FCPA around profit...more

Filing Your Own Return

by Moskowitz LLP on

In our last post, we reviewed the main advantages and disadvantages of joint tax returns for married couples. This post will focus on when a married couple should consider filing separately, and special considerations if they...more

Third Circuit Widens the Circuit Split on Late-Filed Tax Returns

by PretiFlaherty on

The Court of Appeals for the Third Circuit has joined the Fourth, Sixth, Seventh, Eighth, and Eleventh Circuits in employing a four-part test to determine whether debt associated with a late-filed tax return is dischargeable...more

Taxpayer Tips: Best Practices for U. S. Tax Court

Taxpayers contesting IRS assessments of additional taxes, penalties and interest have a number of different options to contest and appeal those assessments. One of those options includes bringing a case to the United States...more

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