For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...more
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
The March 22 deadline for applying to the IRS Voluntary Disclosure Program (VDP) to repay improperly claimed Employee Retention Credits (ERC) at a discount is just around the corner. The VDP requires businesses to repay only...more
As looming collection action efforts against delinquent taxpayers intensifies, the Internal Revenue Service is attempting to increase voluntary compliance and payment for outstanding liabilities. The IRS announced automatic...more
On August 4, 2023, the IRS published proposed regulations that, if finalized, would identify monetized installment sale transactions as a listed transaction. Sellers, intermediaries and other involved parties would be...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
Estate Tax – It’s a Killer- One of the reasons often given for eliminating the estate tax is the substantial economic burden it places upon the estate of a deceased business owner and upon the business itself. Specifically,...more
On 3/31/23, the IRS continued the release of its 2023 annual “Dirty Dozen” List – this time geared towards high income filers by presenting abusive arrangements that involve Charitable Remainder Annuity Trusts and Monetized...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
I recently encountered an interesting situation in which someone suggested that a grantor trust be decanted into a non-grantor trust before the end of the taxable year. The reason? To avoid the special interest charge that...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
Due to COVID-19 the IRS’ People First Initiative provides relief to taxpayers on a variety of issues from easing payment guidelines to delaying compliance actions. This relief is effective through the filing and payment...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
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 (IRS) has just announced a "sweeping series of steps" to help taxpayers address the challenges of COVID-19 related issues. The IRS "People First Initiative," announced Wednesday March 25, 2020,...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