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Reporting Requirements Tax Returns

Allen Barron, Inc.

Don’t Forget About the Beneficial Ownership Information (BOI) Report

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Have you forgotten about the Beneficial Ownership Information (BOI) Report established by the Corporate Transparency Act (CTA) of 2021? Owners of qualifying domestic entities, as well as those qualifying foreign entities...more

Hinshaw & Culbertson LLP

Updated FinCEN FAQs Provide Three Important Clarifications on Reporting Obligations Under the Corporate Transparency Act (CTA)

The Corporate Transparency Act (the CTA) went into effect earlier this year, although many uncertainties about the CTA's application still remain. To help remedy those uncertainties, the Financial Crimes Enforcement Network...more

Allen Barron, Inc.

How Does the IRS Define Willfulness in Unreported or Under-reported Offshore Income

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How does the IRS define willfulness in unreported or under-reported offshore income?  What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct?  Why should U.S. taxpayers be...more

Eversheds Sutherland (US) LLP

Government updates procedures to change R&D, income recognition, and inventory methods in new Rev. Proc. 2024-23

On April 30, 2024, the Internal Revenue Service (IRS) released Rev. Proc. 2024-23, List of Automatic Changes, which provides the list of tax accounting method changes a taxpayer may file under the IRS’s automatic procedures,...more

Allen Barron, Inc.

The Risks of an IRS Quiet Disclosure

Allen Barron, Inc. on

What are the risks of an IRS quiet disclosure? Is there a formal IRS process known as a "quiet disclosure," and does the IRS honor this strategy for amended tax returns?...more

Allen Barron, Inc.

When to Consider the IRS Streamlined Procedures

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What are the IRS streamlined filing compliance procedures (known more commonly as the “streamlined procedures”), and when should a US taxpayer consider the IRS streamlined procedures to come into compliance with IRS reporting...more

International Lawyers Network

Establishing a Business Entity in Spain (Updated)

1. TYPES OF BUSINES ENTITIES - 1.1 Description of the types of entities available in each jurisdiction through which to conduct business - • Limited companies: Corporation and Limited Liability Company - When...more

Foodman CPAs & Advisors

Activos Digitales 2023 Formulario 1040

El 01/22/24, el IRS le recordó a los contribuyentes que deben responder nuevamente a la pregunta sobre activos digitales 2023 en los formularios 1040 y 1040-SR y reportar todos los ingresos relacionados con activos digitales...more

Allen Barron, Inc.

IRS Provides 2023 Tax Return Preparation and Filing Tips

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Are you searching for 2023 tax return preparation and filing tips? The window officially opened to submit 2023 tax returns to the IRS on January 29, 2024. The following day the IRS released IR-2024-38, “Things to remember...more

McDermott Will & Emery

Weekly IRS Roundup December 25 – December 29, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 25, 2023 – December 29, 2023...more

Bodman

A Year-End Reminder: Potentially Overlooked Reporting Requirements

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For many organizations and individuals, the end of the calendar year generates significant reporting obligations, particularly with respect to the Internal Revenue Service. The following requirements may not be obvious, but...more

McDermott Will & Emery

Weekly IRS Roundup November 20 – November 24, 2023

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 20, 2023 – November 24, 2023....more

Allen Barron, Inc.

Are There Strategies to Avoid an IRS Audit?

Allen Barron, Inc. on

Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more

Alston & Bird

How Is Congress Trying to Regulate Private Equity in Health Care?

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Our Health Care Group investigates congressional efforts to require new transparency disclosures to the IRS from private equity firms invested in health care....more

Kohrman Jackson & Krantz LLP

Will The Corporate Transparency Act Affect Estate Planning?

The Corporate Transparency Act of 2020 (CTA) passed through Congress on Jan. 2, 2021. The CTA was enacted to prevent companies from being able to conceal ownership of businesses where concealment could facilitate illicit...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

International Lawyers Network

Establishing A Business Entity In Spain (Updated)

1. TYPES OF BUSINES ENTITIES - 1.1 Description of the types of entities available in each jurisdiction through which to conduct business - • Limited companies: Corporation and Limited Liability Company - When...more

Cadwalader, Wickersham & Taft LLP

Supreme Court Hands Taxpayers a Victory in FBAR Penalty Case

Taxpayers recently won a significant victory at the Supreme Court in a penalty case involving a non-willful failure to file a Report of Foreign Bank and Financial Accounts (“FBAR”) under the Bank Secrecy Act (the “BSA”)....more

Polsinelli

Major Win For Taxpayers: SCOTUS Limits FBAR Penalties to Per Report Not Per Financial Account

Polsinelli on

After years of litigation, the United States Supreme Court, in Bittner v. United States, 598 U.S. ____ (2023), determined that the penalty for a non-willful failure to file a Report of Foreign Bank and Financial Accounts...more

Freeman Law

Section 6751(b) Penalty Approval Circuit Split

Freeman Law on

Eleventh Circuit Sides with Ninth Circuit on Section 6751(b) Circuit Split - Introduction: Section 6751(b) and the Timing of Supervisory Approval of a Penalty - The Eleventh Circuit’s decision in Kroner v. Commissioner,...more

Freeman Law

International Tax Withholding | Chapter 3 of the Internal Revenue Code

Freeman Law on

One of the more confusing areas of international tax law is determining when withholding is required. Getting it wrong can have dire consequences. Currently, U.S. international withholding provisions can be found in...more

Freeman Law

Extended Tax Filing Deadline | Commonly Overlooked Tax Disclosures

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This year the extended tax filing deadline for U.S. citizens or residents, sole proprietorships, C corporations, and single-owner LLCs is Monday, October 17, 2022. Through the course of the tax year companies often engage in...more

Holland & Knight LLP

IRS anuncia amnistía fiscal internacional nueva hasta el 30 de septiembre de 2022

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El servicio de impuestos internos de Estados Unidos (Internal Revenue Service o IRS) recientemente anunció una amnistía nueva que permite presentar ciertas declaraciones de 2019 y 2020 sin multa antes del 30 de septiembre de...more

Holland & Knight LLP

Willful or Non-Willful? That Is the Question: IRS Rejects Non-Willful Certification

Holland & Knight LLP on

In Flint v. United States, 2022 WL 3593826 (Fed. Cl. 2022), the court held that the executors of an estate could not recover a six-figure "Title 26 miscellaneous offshore penalty" (MOP) the decedent paid to the Internal...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

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