On April 5, 2023, Commissioner Daniel I. Werfel issued the Internal Revenue Service Inflation Reduction Act Strategic Operating Plan (“Plan”). The Plan, which spans over 145 pages, is a roadmap to how the Service will deploy...more
The Taxpayer Advocate Service (“TAS”) is an independent body housed within the Internal Revenue Service (the “Service” or “IRS”). Its mission is to ensure taxpayers are treated fairly by the Service and that taxpayers know...more
More than 25 years ago, effective January 1, 1997, Treasury issued what have been called the “Check-the-Box” regulations (the “Regulations”). The Regulations ended decades of battles between taxpayers and the IRS over entity...more
6/17/2022
/ Banks ,
Business Entities ,
Check the Box Rules ,
Disregarded Entities ,
Employment Tax ,
Entity Classification ,
Excise Tax ,
Federal Taxes ,
Gift Tax ,
Income Taxes ,
IRS ,
Tax Liability ,
Tax Planning
Like last year, 2021 has been a difficult year. The COVID-19 pandemic continues to be at the forefront of everyone’s existence. On top of that, the Delta variant and the most recently discovered Omicron variant have entered...more
...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code.
Tax legislation is...more
10/15/2021
/ Asset Valuations ,
Biden Administration ,
Business Losses ,
Business Taxes ,
Capital Gains ,
Capital Gains Tax ,
Carried Interest ,
Carried Interest Tax Rates ,
Contribution Limits ,
Corporate Taxes ,
Death Tax ,
Estate Planning ,
Estate Tax ,
Estate-Tax Exemption ,
Federal Taxes ,
Gift Tax ,
Gifts ,
High Net-Worth ,
Holding Periods ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Net Investment Income ,
Partnership Interests ,
Pending Legislation ,
Qualified Business Income ,
Qualified Small Business Stock ,
Required Minimum Distributions ,
Retirement Plan ,
Tax Deductions ,
Tax Exemptions ,
Tax Legislation ,
Tax Liability ,
Tax Planning ,
Tax Rates ,
Tax Reform ,
Trusts
As many readers have noticed, I have been silent for the past few months. That is partly due to exhaustion from reporting on the flurry of tax events that have occurred since the COVID-19 pandemic commenced in 2020 and also...more
For the second year in a row, the due date for the filing of income tax returns and the payment of taxes was extended. For most taxpayers, the extended deadline brought glee. For the tax return preparation community, however,...more
It is not unreasonable to anticipate that there will be a federal tax policy transformation following a change in the political control of the White House, the U.S. Senate and the U.S. House of Representatives. What may be...more
2/25/2021
/ Business Taxes ,
Capital Gains Tax ,
Corporate Taxes ,
Federal Taxes ,
Gift Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Section 1031 ,
Tax Liability ,
Tax Planning ,
Tax Policy ,
Tax Rates
The Consolidated Appropriations Act, 2021 -
In a bipartisan effort, H.R. 133-116th Congress: Consolidated Appropriations Act, 2021 (the "Consolidated Appropriations Act, 2021") overwhelmingly passed both the House and the...more
12/23/2020
/ Business Expenses ,
Business Taxes ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
Debt ,
Federal Taxes ,
Income Taxes ,
IRS ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
Pending Legislation ,
Tax Deductions ,
Tax Relief ,
Trump Administration
When we thought times were bad enough with the COVID-19 pandemic and widespread social unrest in our country, the West Coast, including the Pacific Northwest, was struck with unprecedented wildfires and massive windstorms,...more
9/18/2020
/ Federal Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Natural Disasters ,
Popular ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Relief ,
Tax Returns ,
Time Extensions ,
Wildfires
As most people are aware, the 2019 income tax filing and payment deadlines for all taxpayers who file and pay their federal income taxes on April 15, 2020, were automatically extended until July 15, 2020. This relief is...more
In News Release 2020-107, issued Thursday, May 28, 2020, the IRS announced that taxpayers will soon be able to electronically file Form 1040-X, Amended U.S. Individual Income Tax Return. This is welcome news for taxpayers and...more
In Notice 2020-32, issued Thursday, April 30th, the IRS emphatically pronounced that taxpayers receiving Paycheck Protection Program (“PPP”) loans do not get to have their cake and eat it too!
As we discussed in a recent...more
5/4/2020
/ Business Expenses ,
CARES Act ,
Coronavirus/COVID-19 ,
Federal Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
Small Business ,
Tax Deductions ,
Tax Planning
NOTICE 2020-23 -
On April 9, 2020, the U.S. Secretary of the Treasury issued Notice 2020-23. It greatly expands the tax compliance relief previously granted to taxpayers in response to the COVID-19 pandemic....more
4/14/2020
/ Annual Filings ,
Coronavirus/COVID-19 ,
Federal Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Opportunity Zones ,
Revenue Procedures ,
Section 1031 Exchange ,
Tax Liability ,
Tax Planning ,
Tax Relief ,
Tax Returns ,
Time Extensions ,
U.S. Treasury
On March 13, 2020, President Trump issued an emergency declaration that, in part, instructed the U.S. Department of the Treasury (“Treasury”) to provide taxpayers with “relief from tax deadlines” due to the impact of the...more
3/30/2020
/ Coronavirus/COVID-19 ,
Federal Taxes ,
Filing Deadlines ,
Generation-Skipping Transfer ,
Gift Tax ,
Income Taxes ,
IRS ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Relief ,
Tax Returns ,
Trump Administration ,
U.S. Treasury
Wednesday, March 25th, in the wake of the recent decision by the Internal Revenue Service (“IRS”) to extend the income tax filing and payment deadlines to July 15, 2020, it announced a new taxpayer-friendly program called the...more
3/30/2020
/ Enforcement Actions ,
Federal Taxes ,
Filing Deadlines ,
Income Taxes ,
Installment Agreements ,
IRS ,
Offers in Compromise ,
Statute of Limitations ,
Tax Appeals ,
Tax Audits ,
Tax Liability ,
Tax Planning ,
Tax Relief ,
Tax Returns
Thursday, March 19th, I reported that the U.S. Department of the Treasury (“Treasury”) issued Notice 2020-17, extending the due date for payment of federal income taxes from April 15, 2020 to July 15, 2020, because of the...more
On March 13, 2020, President Trump issued an emergency declaration, which in part instructed the U.S. Department of the Treasury (“Treasury”) to provide taxpayers with “relief from tax deadlines” due to the impact of the...more
3/20/2020
/ C-Corporation ,
Coronavirus/COVID-19 ,
Federal Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Tax Deferral ,
Tax Liability ,
Tax Penalties ,
Tax Planning ,
Tax Relief ,
Tax Returns ,
Trump Administration ,
U.S. Treasury
New York Attorney General Barbara Underwood and New York Governor Andrew Cuomo announced today that the state of New York, joined by the states of Connecticut, New Jersey and Maryland, have instituted a lawsuit against the...more
7/18/2018
/ 16th Amendment ,
Constitutional Challenges ,
Federal Taxes ,
Governor Cuomo ,
Income Taxes ,
IRS ,
Itemized Deductions ,
SALT ,
Secretary of the Treasury ,
State Attorneys General ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tenth Amendment ,
Trump Administration
As reported in my November 2014 blog post, President Obama’s administration wants to limit taxpayers’ ability to defer income under IRC § 1031. In response to former House Ways and Means Committee Chairman David Camp’s...more