News & Analysis as of

Internal Revenue Code (IRC) Failure to Comply

Foodman CPAs & Advisors

Forms 3520 and 3520-A Late Filing get IRS Relief

On 10/24/24, the National Taxpayer Advocate shared on its NTA Blog that the IRS has discontinued its policy of automatically imposing penalties for late submissions of Form 3520, which pertains to foreign gifts and...more

Kramer Levin Naftalis & Frankel LLP

IRS: Affordable Care Act Penalties Go On … and On … Forever?

The Internal Revenue Service (IRS), in a recently released memorandum from the Office of Chief Counsel (Chief Counsel Memorandum), has taken the position that the Employer Shared Responsibility Payment (ESRP) imposed by...more

Foodman CPAs & Advisors

Indirect linkages to Tax Havens

Foodman CPAs & Advisors on

The U.S. income tax system is based on the idea of voluntary taxpayer compliance. It is the taxpayer’s responsibility to report all reportable worldwide income. Some people attempt to evade paying taxes by failing to report...more

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