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Ballard Spahr LLP

IRS Changes Course on Income Tax Impact of Employee Retention Credit

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On March 20, 2025, the IRS updated its guidance to employers that claimed the employee retention credit (ERC). The updated guidance materially differs from prior IRS guidance of how and when employers should report the income...more

Jones Day

New Proposed Regulations Address Spin-Off Transactions

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These proposed regulations applicable to tax-free spin-offs would impose a range of new substantive requirements and greatly expand the information that must be reported to the Internal Revenue Service ("IRS") by taxpayers...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

Freeman Law

You Received an IRS Notice CP2000, Now What?

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You might receive an IRS Notice CP2000 (“CP2000”) in the mail. The IRS issues these particular notices to taxpayers based on discrepancies between tax return reporting and third-party reporting. Taxpayers must pay attention...more

Foodman CPAs & Advisors

How Will Virtual Currency Be Taxed?

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Despite the confusing interpretations by US regulators, non-compliance with crypto tax rules can cost taxpayers dearly. Unfortunately, the answer to “how is virtual currency taxed” depends on who you ask....more

Foodman CPAs & Advisors

Closing A Foreign Bank Account Will Not Solve A Taxpayer’s Disclosure Problem

IRS is interested in U.S. Taxpayer financial accounts everywhere in the world.  If the IRS learns that a Taxpayer has undisclosed reportable accounts or income before a US Taxpayer reports them, the Taxpayer can face serious...more

Foodman CPAs & Advisors

IRS issues FATCA Relief but not for All

On September 6, 2019, IRS announced Relief Procedures for Certain Former Citizens.  These are procedures for certain persons who have relinquished, or intend to relinquish, their United States  citizenship, who wish to come...more

Orrick - On the Chain

IRS Hints at Form 8938 Requirements for Reporting Crypto Assets Held at a Foreign Exchange

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With the emergence of digital assets, the question has arisen whether digital assets held in “wallets” in foreign exchanges need to be reported on Internal Revenue Service (IRS) Form 8938, Statement of Specified Foreign...more

Kramer Levin Naftalis & Frankel LLP

Virtual Currency

On Oct. 9, 2019, the Internal Revenue Service (the “Service”) issued Revenue Ruling 2019-24 concerning the tax consequences of virtual currency hard forks, as well as FAQs on the taxation of virtual currency generally. This...more

Foodman CPAs & Advisors

Taxpayers, have you sold, received, exchanged or acquired Virtual Currency?

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During the month of October 2019, IRS issued Revenue Ruling 2019-24,  FAQ’s on Virtual Currency Transactions and a DRAFT Form of Schedule 1,  which, for the first time presents the question:  “At any time during 2019, did you...more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

Lowndes

Don’t Forget to File Your Foreign Bank Account Return

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If you have a foreign bank account (or signatory authority on a foreign bank account), you are required to file a Form 114 (commonly called an FBAR) if at any point during the calendar year the combined balance in all of your...more

Butler Snow LLP

Non-US Persons Holding US Real Estate: Penalties For Failing To File Certain IRS Forms Are Increasing To $25,000

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Most non-US persons who are properly advised regarding US real estate ownership will structure their holdings to include some combination of US LLCs, non-US companies, non-US partnerships, non-US trusts and/or non-US...more

Foodman CPAs & Advisors

Tenga Cuidado con la Campaña de Precisión de Presentación de FATCA del IRS

El 30 de octubre del 2018, la división Internacional y de Grandes Empresas del IRS (“LBI”) anunció la aprobación de una campaña de cumplimiento que incluye cómo las Instituciones Financieras Extranjeras (“FFIs)) y ciertas...more

Foodman CPAs & Advisors

What we know about Crypto Compliance and US Federal Taxes

The last Notice issued by the IRS on Cryptocurrency was Notice 2014-21 posted on March 25, 2014 providing guidance in the form of answers to frequently asked questions. ...more

Foodman CPAs & Advisors

Bitcoins y el IRS: Reportaje y Almacenamiento

La posesión de moneda virtual, también conocida como criptomoneda, es legal tanto en los EE.UU como en muchas otras partes del mundo. La forma más conocida de moneda virtual es Bitcoin. ...more

Foodman CPAs & Advisors

Thoughts about the New Filing Requirements for Foreign-Owned U.S. entities?

Foreign Persons that own 25% of a US entity might want to reassess their strategy as it relates to that ownership. It “used to be” (until December, 2016) that a Foreign Person as a single owner of a Limited Liability Company...more

Burr & Forman

IRS Announces End to Foreign Bank Account Disclosure Program: What Can You Do Now If You Still Have Unreported Foreign Bank...

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The IRS recently announced it will be shutting down its successful Offshore Voluntary Disclosure Program (OVDP) for unreported foreign bank accounts and income. The program will end September 28, 2018. Under the OVDP, first...more

Foodman CPAs & Advisors

Many are now looking for IRS Guidance on Virtual Currency

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Due to its unprecedented level of value appreciation, Bitcoin investors, consumers and businesses are looking for IRS Guidance. IRS recognizes that “virtual currency” may be used to pay for goods or services, or be held for...more

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