News & Analysis as of

Audits Internal Revenue Code (IRC)

Foodman CPAs & Advisors

ERC Voluntary Disclosure Program Re-Opens

On 7/15/24, the IRS announced via Notice IR-2024-212 the re-opening of the ERC (Employee Retention Credit) Voluntary Disclosure Program which will end on 11/22/24. The first ERC Voluntary Disclosure Program ended in March...more

Fox Rothschild LLP

IRS Reopens Employee Retention Tax Credit Voluntary Disclosure Program

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The ERC is a legitimate, refundable tax credit designed to help businesses that continued to pay employees while they were shut down because of the COVID-19 pandemic or that experienced a significant decline in gross receipts...more

Holland & Knight LLP

IRS Targets Owners of Professional Sports Franchises Regarding Tax Reporting

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Basketball just wrapped up its season and hockey is in the last period of its season, but there is no summer vacation for the IRS Large Business and International (LB&I) division. The IRS recently announced a new enforcement...more

Farella Braun + Martel LLP

The IRS Is Targeting Partnership Transactions: Is Your Representative Ready?

Earlier this week, Treasury and the IRS issued guidance to halt the use of partnership rules in the Internal Revenue Code to engage in abusive basis-shifting transactions whereby tax basis is stripped from certain assets and...more

Greenberg Glusker LLP

Decoding Franchise Tax Board’s Hot Button Areas: Drops and Swaps and Post-Closing Refinancing

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Those of us in California who give advice regarding the structuring of IRC Section 1031 like-kind tax-deferred exchanges of real property are well aware that the California Franchise Tax Board (FTB) has an active program of...more

Rivkin Radler LLP

Missing the Tax Court’s 90-Day Deficiency Deadline – Now What?

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Over the years, I have observed there is only one thing that a taxpayer fears more than being notified by the IRS that their income tax return for a particular taxable year has been selected for audit, and that is being...more

Holland & Knight LLP

U.S. Tax Court Holds Bond Financing Costs Are Includible in LIHTC Basis

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A U.S. Tax Court decision entered on Feb. 20, 2024, in 23rd Chelsea Associates LLC v. Commissioner of Internal Revenue held that bond issuance and related financing costs incurred in connection with the development of a...more

Pillsbury Winthrop Shaw Pittman LLP

President Biden and Senators Support the Ramp Up in IRS Audits on Corporate Aircraft

President Biden announced that he will focus on ending tax breaks for corporate aircraft and “cracking down on corporate jet loopholes.” Several aviation and labor organizations, including the National Business Aviation...more

McDermott Will & Emery

TTB Ramps Up Tax Audits and Enforcement

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The Alcohol and Tobacco Tax and Trade Bureau’s (TTB) Office of Field Operations is responsible for ensuring industry members comply with the Federal Alcohol Administration Act, the Internal Revenue Code and all related...more

Womble Bond Dickinson

IRS Continues Aggressive Oversight and Enforcement of Employee Retention Credits

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The Employee Retention Credit (ERC) is a refundable tax credit for businesses whose employees were impacted by the COVID-19 Pandemic. The provisions are set out in § 2301 of the CARES Act and § 3111 of the Internal Revenue...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Ramps Up Audits on Corporate Aircraft Use for High-Net-Worth Individuals and Affiliated Entities

The Internal Revenue Service (IRS) is increasing audits on corporate aircraft use for high-net-worth individuals, large corporations and complex partnerships as part of its new initiative using Inflation Reduction Act funding...more

Eversheds Sutherland (US) LLP

IRS sees flight risk with corporate jets

On February 21, 2024, the IRS announced a new initiative to audit large corporate taxpayer use of corporate jets, as part of a larger initiative focused on tax compliance of large corporations and high-income taxpayers. The...more

Seward & Kissel LLP

For Fund Managers, Tax Court Ruling Sets Limited Partners Back “As Such”

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Memorandum to our Investment Management Clients and Friends - The United States Tax Court recently issued a ruling (the “Ruling”) pertaining to the possible exclusion of a limited partner’s distributive share of income...more

Davis Wright Tremaine LLP

IRS Delays SECURE 2.0 Roth Requirement for Catch-up Contributions Until 2026

On Friday, Aug. 25, 2023, the IRS announced a two-year reprieve for employers on the implementation of SECURE 2.0's requirement that catch-up contributions made by higher-income participants be designated as after-tax Roth...more

Bricker Graydon LLP

Why Time is of the Essence More than Ever in Correcting Retirement Plan Errors

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Errors in retirement plans happen even to the most well-intentioned plan sponsors. Several decades ago, the IRS published the first version of the Employee Plans Compliance Resolution Program (EPCRS), which outlines...more

Epstein Becker & Green

Local Law Amends New York City Charter and Establishes an Office of Healthcare Accountability

On June 8, 2023, the New York City Council passed a bill focused on healthcare accountability, with the goal of increasing access to healthcare services for New Yorkers. Entitled the Healthcare Accountability & Consumer...more

Proskauer Rose LLP

Wealth Management Update - June 2023

Proskauer Rose LLP on

June 2023 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The June Section 7520 rate for use in estate planning techniques such as CRTs, CLTs, QPRTs...more

Holland & Hart LLP

Finally, Good News from the IRS: Cannabis Operators Could Be Eligible for the Qualified Business Income Deduction

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If you didn’t attend the American Bar Association’s Section of Taxation meeting last week, you may have missed that IRS Counsel confirmed they will not automatically challenge a Section 199A qualified business income...more

Proskauer - Employee Benefits & Executive...

SECURE 2.0 Delivers New Rules for Correcting Retirement Plan Errors

As part of our ongoing series on SECURE 2.0, this post discusses three significant changes to corrections of common retirement plan errors: (1) New rules for correcting overpayments, (2) expansion of the Self-Correction...more

Pullman & Comley - Labor, Employment and...

Mortgage or other Third Party Loan Investments in Your Plan?  Do they Pass Muster under IRS Issue Snapshot?

The IRS Issue Snapshot-Third Party Loans from Plans dated August 23, 2022 is a short advice document for examiners to use when auditing tax-qualified retirement plans that invest in mortgages or other third party loans. IRS...more

Foley & Lardner LLP

401(k) Compliance Check #7: Five Administrative Policies Every 401(k) Plan Needs

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To help employers properly administer their 401(k) plans, in 2022, Foley & Lardner LLP is authoring a series of monthly “401(k) Compliance Check” newsletters. This article discusses some of the policies that are important for...more

Foley & Lardner LLP

401(k) Compliance Check #6: Have You Recently Checked Your 401(k) Plan’s Definition of Compensation for Deferral and Match...

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In last month’s Compliance Check, we discussed how to handle a situation where the 401(k) plan administrator is unable to reach a plan participant, i.e., a “missing participant.” In this month’s Compliance Check, we focus on...more

Verrill

Required Minimum Distributions and Missing Plan Participants

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In January of 2021, we published two blog posts regarding Department of Labor (“DOL”) guidance on missing retirement plan participants. The first post describes DOL guidance on best practices for locating missing retirement...more

McDermott Will & Emery

Extending the Statute of Limitations for Assessing Federal Tax

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We previously provided an overview of the time limits imposed on the Internal Revenue Service (IRS) for assessing federal tax. The general rule is that the IRS must assess tax within three years from the later of the due date...more

BCLP

EO Update: e-News for Charities & Nonprofits - September 2021

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Updated Procedures Related to Direct Contact in the Determination Process - On August 17, 2021, Exempt Organizations Rulings & Agreements (EO R&A) office issued Interim Guidance (IG) memorandum (TEGE-07-0821-0016) on...more

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