News & Analysis as of

Reporting Requirements Internal Revenue Service Statute of Limitations

Smith Anderson

Welcomed Changes to Affordable Care Act Information Reporting for 2025

Smith Anderson on

Two new laws signed on December 23, 2024, are set to make Affordable Care Act (“ACA”) reporting easier and less time-consuming. The 'Paperwork Burden Reduction Act' and the 'Employer Reporting Improvement Act' introduce...more

Lerch, Early & Brewer

Tenth Circuit Affirms Deficiencies, Penalties for Offshore Income

Lerch, Early & Brewer on

Harrington v. Commissioner - In Harrington v. Commissioner of Internal Revenue, George S. Harrington (Harrington) challenged tax deficiencies and fraud penalties assessed for tax years 2005 through 2010. Originally...more

Freeman Law

Everything That You Need To Know About International Tax Penalties

Freeman Law on

International information return penalties are civil penalties assessed by the IRS against a United States person for failing to timely file complete and accurate international information returns required by specific...more

Epstein Becker & Green

IRS Memo Concludes No There Is Statute of Limitations for ACA Employer Mandate Penalties Under Internal Revenue Code § 4980H

The IRS Office of Chief Counsel recently issued a memo which, in a surprise to many, concluded that the filing of the Affordable Care Act (“ACA”) Forms 1094-C and 1095-C (“C Forms”) does not start the statute of limitations...more

Cozen O'Connor

IRS Asserts No Statute of Limitations for ACA Violations; May Require New Record Retention Policies

Cozen O'Connor on

When it comes to complying with the law, the expiration of a statute of limitations can be a welcome relief for employers trying their best to be legally compliant, but discovering that they were not 100 percent correct with...more

Rosenberg Martin Greenberg LLP

What to Do (and Not Do) to Resolve Your Offshore Tax Issues

In recent months, the Internal Revenue Service (“the Service”) began the process of issuing follow-up letters to taxpayers who either requested preclearance to participate in the Offshore Voluntary Disclosure Program (“OVDP”)...more

Bowditch & Dewey

New Reporting Regime: Estates Who Have to File Federal Estate Tax Returns Need to be Aware of New Basis Consistency Law

Bowditch & Dewey on

On July 31, 2015, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 introduced new tax law that affects executors who are required to file a federal estate tax return and beneficiaries...more

Franczek P.C.

Employee Benefits Alert - August 2015

Franczek P.C. on

Retirement Plans - IRS Issues Guidance on Benefit Suspension Voting under MPRA - As we have written in prior alerts, the Multiemployer Pension Reform Act of 2014 (MPRA) permits trustees of financially troubled...more

Morgan Lewis

Highway Funding Bill Includes Significant Changes to Tax Rules

Morgan Lewis on

Unexpected changes in FBAR, corporate and partnership returns, and statute of limitations and mortgage reporting tax rules are embedded in funding bill H.R. 3236. When US President Barack Obama extended funding for...more

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