IRS issued Tax Tip 2024-37, April 24, 2024, to inform taxpayers that can’t pay their full tax debt or if paying would cause financial hardship, that they should consider applying for an offer in compromise which is a program...more
Monetized installment sale transactions (“MISTs”) have been on the IRS’s radar for some time. On May 7, 2021, IRS Chief Counsel issued an advice memorandum, contending such transactions were “problematic” and “flawed”. And...more
The IRS has for the second time in as many years included monetized installment sales on its annual “Dirty Dozen” tax schemes list. As we discussed in a prior post, the “Dirty Dozen” list alerts taxpayers and practitioners to...more
This quarterly newsletter explores the emerging legal topics related to business succession planning. Thought-leading attorneys from Moritt Hock & Hamroff’s Closely-Held/Family Business Practice Group share their legal...more
Sale of the Business- Imagine Client has just received an attractive, all cash offer for the sale of their business; there is no financing contingency. The buyer has proposed a cash-free and debt-free deal....more
Go After Real Estate? During the 2020 presidential campaign, there was one segment of the “rich” for which then-candidate Biden seemed to have reserved some of his harshest criticism – wealthy real estate investors....more
Changes Include Beneficial Payment Plan Options, Less Financial Disclosure for Many with Balances Due, and Ability to Delay Collection Actions - This has been a difficult year for many American taxpayers. In recognition...more
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
Distressed Businesses, the Unemployed, and Others Experiencing Financial Hardship May Greatly Benefit if Action is Taken - Although the pandemic and related financial downturns have put many individuals and businesses on...more
On April 9, 2020, the Secretary of the U.S. Department of Treasury (the “Secretary”) and the Internal Revenue Service (the “IRS”) issued Notice 2020-23 (the “Notice”), which extends the deadline for performance of a long list...more
The Treasury Department and the Internal Revenue Service offered relief from federal tax return filing and tax payment deadlines to certain taxpayers under Notices 2020-17 and -18. Such federal extension of time to file l...more
Initiative Temporarily Suspends Many Payment Requirements and Enforcement Actions Earlier this week, the Internal Revenue Service (“the Service”) unveiled its new People First Initiative (“the Initiative”), an effort by...more
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
March 25, 2020 – The IRS announced a major suspension of many “tax compliance” dates and tax collection measures. Published in IRS Information Release 2020-59 as the “People First Initiative”, the IRS announced that it is...more
The Internal Revenue Service released a Q&A on Notice 2020-18 to clarify the relief available to taxpayers during the Coronavirus (COVID-19) pandemic. The Q&A offers important new details on the federal income tax filing and...more
Updated on 3/26/20 - In order to combat the adverse economic effects in which many individuals and businesses are experiencing as a result of the COVID-19 outbreak, the federal government and the State of California will...more
Seyfarth Synopsis: To provide relief to taxpayers affected by the 2019 Novel Coronavirus disease (“COVID-19”), the U.S. Treasury Department and Internal Revenue Service postponed the April 15, 2020 due date for filing federal...more
The IRS has released new informal guidance (“Questions and Answers”) regarding section 965, containing information on making successive installment payments, filing transfer agreements as a result of certain acceleration or...more
Many Taxpayers might be faced with an unexpected tax bill during the 2018 Tax season. Many Taxpayers did not alter their tax withholding in their paychecks to reflect the changes in the Tax Reform. ...more
The IRS recently announced that it will be extending the streamlined payment plan pilot program through September 30, 2018. The plan allows taxpayers with federal tax liabilities up to $100,000 to qualify for streamlined...more
One of the most important factors to consider in any business succession plan is the timing of the transition of ownership. Whether a sale or a gift (or combination of the two), no transition should occur before the next...more