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DLA Piper

Top Ten State Tax Considerations for Israeli Companies Operating in the US

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Although Israeli companies operating in the US often focus on federal tax concerns, US state and local taxes (SALT) have the potential to significantly increase tax liabilities. For example, if a company does not collect...more

Ballard Spahr LLP

IRS Changes Course on Income Tax Impact of Employee Retention Credit

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On March 20, 2025, the IRS updated its guidance to employers that claimed the employee retention credit (ERC). The updated guidance materially differs from prior IRS guidance of how and when employers should report the income...more

Jones Day

New Proposed Regulations Address Spin-Off Transactions

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These proposed regulations applicable to tax-free spin-offs would impose a range of new substantive requirements and greatly expand the information that must be reported to the Internal Revenue Service ("IRS") by taxpayers...more

Bowditch & Dewey

Major 2024 Changes for Individual Massachusetts Taxpayers

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Due Date - The due date for Massachusetts Income Tax Returns is April 15, 2025. Income Tax Rate - The tax rate on most types of taxable income is 5%. The tax rate on long-term gains from the sale or exchange of...more

Foodman CPAs & Advisors

Impuestos 2023: Lo Mejor Es Prepararse Ahora

La planificación fiscal le aplica a todos. El 1/22/24, el IRS le recordó a todos los contribuyentes que comenzaran a prepararse para presentar su declaración de impuestos federales sobre la renta. Planificar con anticipación...more

Foodman CPAs & Advisors

2023 Taxes: Best To Get Ready Now

Tax planning applies to everyone. On 1/22/24, IRS reminded all taxpayers to start getting ready to file their federal income tax return. Planning ahead can help taxpayers file an accurate return and avoid delays that can slow...more

Allen Barron, Inc.

IRS Provides 2023 Tax Return Preparation and Filing Tips

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Are you searching for 2023 tax return preparation and filing tips? The window officially opened to submit 2023 tax returns to the IRS on January 29, 2024. The following day the IRS released IR-2024-38, “Things to remember...more

Weber Gallagher Simpson Stapleton Fires &...

2022 Tax Season: What Families Need to Know

As the 2022 tax season kicks off, there are important issues that divorcing parties must consider. First, it is always more beneficial to the family unit for the parties to file taxes married filing jointly. Not only does...more

Freeman Law

Procedimiento simplificado ante el IRS para extranjeros fuera de EUA

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Muchos ciudadanos americanos que viven en el extranjero no presentan su declaración de impuestos en Estados Unidos de América (“EUA”) por diversas cuestiones. Generalmente, esto sucede porque se tiene la creencia que no es...more

Dorsey & Whitney LLP

DSU Plans May Run Afoul of U.S. Deferral Election Timing Rules Resulting in Adverse U.S. Tax Treatment

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A Canadian company adopting a deferred share unit plan (DSU plan) for its directors must consider U.S. tax implications for U.S. taxpayers. It is important to remember that U.S. citizens and U.S. residents for tax purposes...more

Freeman Law

Is a Stiftung a Foreign Trust? Form 3520 Penalties?

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In the recent case of Rost v. United States, the Fifth Circuit analyzed whether a foreign entity should be classified as a foreign trust subject to IRS Form 3520 penalties.  The case arose in the context of a Liechtenstein...more

Freeman Law

How Do I Know if I Have an IRS Form 3520/3520-A Filing Obligation?

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Interests in or transactions with foreign trusts can cause headaches for federal income tax purposes. Depending on the interest or transactions at issue, U.S. citizens or residents may have to file a Form 3520, a Form...more

Freeman Law

How to Successfully Fight the Section 6721(e) Intentional Disregard Penalty

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Section 6721 provides the IRS with authority to impose civil penalties against taxpayer-employers who fail to timely file correct information returns (e.g., Forms W-2/W-3 and Forms 940/941). Under section 6721’s three-tiered...more

Freeman Law

You Received an IRS Notice CP2000, Now What?

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You might receive an IRS Notice CP2000 (“CP2000”) in the mail. The IRS issues these particular notices to taxpayers based on discrepancies between tax return reporting and third-party reporting. Taxpayers must pay attention...more

Gray Reed

How to Handle IRS Notices and Tax Bills

Gray Reed on

The multiple rounds of stimulus checks as part of the COVID-19 relief legislation may have people believing that mail from the IRS is not always bad news. However, aside from isolated situations, most people still flinch at...more

Morgan Lewis

IRS Extends Temporary Use of Electronic and Digital Signatures for Certain IRS Forms Until December 31, 2021

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The US Internal Revenue Service (IRS) extended its temporary approval of accepting digital signatures on certain IRS forms until December 31, 2021 (see Memorandum NHQ-10-1220-000, the Memorandum). This Memorandum has also...more

Foodman CPAs & Advisors

Closing A Foreign Bank Account Will Not Solve A Taxpayer’s Disclosure Problem

IRS is interested in U.S. Taxpayer financial accounts everywhere in the world.  If the IRS learns that a Taxpayer has undisclosed reportable accounts or income before a US Taxpayer reports them, the Taxpayer can face serious...more

Foodman CPAs & Advisors

Have You Hired the Right Tax Preparer to Prepare your Taxes?

Tax Season is here.  Tax Preparers have different levels of skills, education and expertise and Taxpayers ought to take a closer look at what constitutes a “Qualified” Tax Preparer.  ...more

Foodman CPAs & Advisors

19 Possible Questions That Your Tax Preparer Ought to Ask Regarding Foreign Accounts and Assets

Many Taxpayers with international entanglements seek the assistance of tax return preparers without U.S. international tax reporting experience.  Because US International tax reporting is complicated and often overwhelming...more

Freeman Law

How to Successfully Request IRS Penalty Relief

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Federal tax penalties have always been an IRS priority.  But, perhaps more so today than three decades ago.  For example, in 1987, the IRS reported that it had assessed penalties of approximately $14 billion.  Compare that...more

Morgan Lewis

IRS Approves Temporary Use of Digital Signatures for Certain Forms

Morgan Lewis on

The US Internal Revenue Service (IRS) issued news release IR-2020-194 on August 28, approving the temporary use of digital signatures for certain IRS forms that must be filed with the IRS manually. ...more

Foodman CPAs & Advisors

Treasury and IRS are Aiming to Provide Greater Clarity on International Tax Reporting

On July 14, 2020, the US Treasury Department and the IRS released a proposed redesigned partnership form for tax year 2021 (filing season 2022). The two proposed forms SCHEDULE K-2 (Form 1065) and Schedule K-3 (Form 1065) are...more

Foodman CPAs & Advisors

How does IRS Identify Cases with Audit Potential?

Understanding how the IRS identifies cases that have audit potential can be learned from the CONGRESS OF THE UNITED STATES (CONGRESSIONAL BUDGET OFFICE) Report released on July, 2020: Trends in the Internal Revenue Service’s...more

Foodman CPAs & Advisors

What happens when Taxpayers try to tell the IRS that it is not “Mea Culpa”?

According to the IRS Manual, reasonable cause for abating penalties is based on all the facts and circumstances of a Taxpayer’s situation.  IRS will consider reasons which establish that a Taxpayer used all ordinary care and...more

Foodman CPAs & Advisors

So much of Virtual Currency is still subject to Interpretation

On February 12,2020, the U.S. Government Accountability Office (GAO) published a Report  on Virtual Currencies which discusses whether Taxpayers  who use Virtual Currency (VC) are fully meeting their tax obligations.  ...more

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