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Internal Revenue Code (IRC) Penalties

Dickinson Wright

ACA Reporting Update: Some Relief and Process Streamlining for Employers

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Applicable large employers (“ALEs”) are subject to reporting requirements under the Affordable Care Act (the “ACA”). To comply with the reporting requirements, an ALE must file a Form 1095-C with the IRS reporting certain...more

Womble Bond Dickinson

Micro-Captive Reportable Transaction Deadline Effectively Extended

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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

Rivkin Radler LLP

Observations on Charities, Taxes, and Cash Flow

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Few provisions of the Code have a single, clear meaning that leaves no room for interpretation. Even many of those that, on the surface, appear fairly straightforward, are usually open to alternative “understandings.”...more

Holland & Knight LLP

IRS Releases Form 4255 to Report Prevailing Wage and Apprenticeship Penalty Amounts

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The IRS recently released an updated Form 4255, Certain Credit Recapture, Excessive Payments, and Penalties, which is used to report the amount due for certain credit recaptures, excessive payments, excessive credit transfers...more

Lippes Mathias LLP

Taxpayer Beware: The Pitfalls of Section 965 Installment Payments

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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

Proskauer - Employee Benefits & Executive...

New “Self-Correction” Option for Voluntary Fiduciary Correction Starts March 17, 2025

Starting March 17, 2025, the Employee Benefits Security Administration’s Voluntary Fiduciary Correction Program (“VFCP”) will have a “self-correction” option. Although the new option eliminates the need to wait for formal...more

Baker Botts L.L.P.

Taxpayer Assistance and Service Act – Tax Controversy Perspective

Baker Botts L.L.P. on

On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a legislative proposal that, if passed, could significantly alter tax controversy...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

You’ll get hammered if you don’t use the DFVCP

I sound like a broken record, but I won’t stop until 401(k) plan sponsors understand the issue of a late Form 5500 and Internal Revenue Service (IRS) and Department of Labor (DOL) penalties....more

Husch Blackwell LLP

Impending IRS Workforce Cuts Mean Taxpayers Should Act Now to Resolve IRS Issues

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The New York Times reported on March 4, 2025, that the Trump administration is aiming to cut half of the Internal Revenue Service’s workforce by the end of the year. The cuts are reportedly across all divisions of the IRS,...more

Proskauer - Tax Talks

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

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On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more

Bricker Graydon LLP

Do I Need a 409A Valuation for my Company?

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If you have equity as part of your retirement or executive compensation plans, you likely need a 409A valuation. The need for a valuation also applies if you are preparing to issue equity (equity grants or stock options) or...more

Allen Barron, Inc.

The Taxpayer Bill of Rights - 10 Essential Rights for U.S. Taxpayers

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Are you aware of the Taxpayer Bill of Rights?  We are reminded, especially during tax season, that taxpayers have 10 essential rights when dealing with the Internal Revenue Service. The IRS expects its employees to understand...more

Offit Kurman

Not Realizing the True Value of “Stuff”

Offit Kurman on

For federal estate and gift tax purposes, transfers are valued at the “fair market value” of the asset on the date of transfer. One of the more common estate tax audit issues is the failure to properly report the value of...more

Freeman Law

Posts, Profits, & Penalties | Tax Law & Social Media | Part 2

Freeman Law on

Cristiano Ronaldo was 2024’s highest-earning Instagram influencer, receiving approximately $3.23 million per post. This jaw-dropping number is not the typical amount that Instagram influencers earn. In fact, on average,...more

Latham & Watkins LLP

Treasury Finalizes Controversial Regulations on IRS Penalty Oversight, but Debate Continues

Latham & Watkins LLP on

Section 6751(b), designed to ensure supervisory oversight amid rising penalty assertions in settlement negotiations, has been contentious due its ambiguity, and the final regulations may not resolve the debate....more

Bass, Berry & Sims PLC

2025 Changes to ACA Employer Information Reporting Obligations and the Employer Shared Responsibility Penalties

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In December 2024, Congress and President Biden passed two laws—the Paperwork Burden Reduction Act (PBRA) and the Employer Reporting Improvement Act (ERIA)—that made important changes to employers’ responsibilities regarding...more

Ropes & Gray LLP

IRS Issues Final Regulations Requiring Disclosure of Certain “Basis Shifting” Transactions Involving Partnership Distributions and...

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The U.S. Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations on January 14, 2025 (the “Regulations”) requiring taxpayers and their material advisors to disclose...more

Orrick, Herrington & Sutcliffe LLP

Annual Reporting Requirements for Incentive Stock Options and Employee Stock Purchase Plans - January 2025

Annual Information Statements and IRS Returns Requirement to Report For (1) any exercise of an incentive stock option (ISO) during 2024 or (2) transfer during 2024 of a share previously purchased pursuant to a tax-qualified...more

Freeman Law

National Taxpayer Advocate’s Annual Report Highlights Issues Plaguing the IRS

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In her annual report to Congress for 2024, National Taxpayer Advocate (“NTA”) Erin M. Collins identified the processing of Employee Retention Credits (“ERCs”), the administration of civil penalties, and changes to the...more

Kilpatrick

Approaching Deadline: Reporting for ISO Exercises and ESPP Stock Transfers Due Beginning January 31, 2025

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This alert is a reminder of the approaching deadlines for certain year-end reporting requirements applicable to corporations that issue stock to employees (including former employees) upon the exercise of certain stock...more

Fenwick & West LLP

IRS Filing and Reporting Requirements for ISO Exercises and ESPP Stock Transfers - January 2025

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The IRS has issued two forms (along with accompanying instructions) that corporations must use to satisfy the return and information statement requirements under Section 6039 of the Internal Revenue Code of 1986, as amended....more

Goodwin

Deadline Approaching for Reporting 2024 ISO Exercises and ESPP Share Transfers

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The Internal Revenue Code requires corporations to provide information statements to employees (including former employees) and information filings to the IRS regarding exercises of incentive stock options (ISOs) by employees...more

Buchalter

Tax Relief and Recovery: Key Considerations for Los Angeles Residents Affected by Recent Wildfires

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We at the Buchalter law firm understand that many have suffered greatly as a result of the recent wildfires. The loss of life, and the loss of homes with memories is, of course irreplaceable....more

Cooley LLP

Year-End Reporting for ISO Exercises and ESPP Stock Transfers - January 2025

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This alert serves as a reminder of certain year-end reporting requirements imposed under Section 6039 of the Internal Revenue Code of 1986, as amended, with respect to...more

Cole Schotz

RetireReady NJ: Reminder About The Requirements Under The New Jersey Secure Choice Savings Program Act

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Employers with at least 25 employees in New Jersey that do not already offer a qualified retirement plan to employees must take action to facilitate the RetireReady NJ Retirement Savings Program (“RetireReady NJ”)....more

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