News & Analysis as of

Internal Revenue Code (IRC) Filing Deadlines Tax Penalties

Womble Bond Dickinson

Micro-Captive Reportable Transaction Deadline Effectively Extended

Womble Bond Dickinson on

On Friday, April 11, 2025, the Internal Revenue Service issued Notice 2025-24 (the “Notice”), which waives applicable penalties under the Internal Revenue Code to participants in, and material advisors to, reportable...more

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

Rivkin Radler LLP

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

Rivkin Radler LLP on

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

Freeman Law

Reasonable Cause: An Estate’s Defense Against IRS’s Late-Filing Penalties

Freeman Law on

The Internal Revenue Code (the “Code”) contains over 150 civil tax penalties for various conduct and non-conduct. One common group of penalties, associated with the late filing of a tax return and the late payment of tax,...more

Brownstein Hyatt Farber Schreck

IRS Expands Self-Correction of Retirement Plan Errors

In guidance issued on April 19, 2019, the IRS expands the situations in which retirement plan sponsors can self-correct compliance failures without first having to seek IRS approval or paying a fee. Employers should be aware...more

McDermott Will & Emery

Reasonable Cause for E-Filing Errors?

Tax return filing season is fast approaching, and taxpayers big and small are preparing to file their returns. A recent US Court of Appeals for the Fifth Circuit decision, Haynes v. United States, No. 17-50816 (5th Cir. Jan....more

Bradley Arant Boult Cummings LLP

IRS Updates EPCRS Plan Correction Procedure - Employee Benefits Alert

Through Revenue Procedure 2018-52, the Internal Revenue Service (IRS) has recently updated its system of correction programs for retirement plans known as the Employee Plans Compliance Resolution System (EPCRS). EPCRS permits...more

Mintz - Employment, Labor & Benefits...

The Affordable Care Act’s Reporting Requirements for Carriers and Employers (Part 4 of 24): Highlights from the Draft 2015...

The IRS recently issued draft 2015 Instructions for Forms 1094-C and 1095-C (“2015 Instructions”). These are the forms that employers with 50 or more full-time employees (including full-time equivalent employees) in the...more

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