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Lathrop GPM

First Time Issuance of IRS Form for Elections Under Section 83(b)

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For the first time, the IRS has issued an official form to be used for making an election under Section 83(b) of the Internal Revenue Code. Until the IRS issued Form 15620 in late 2024, taxpayers used their own “homemade”...more

Keating Muething & Klekamp PLL

Sale of QSBS and Installment Sale Reporting

In recent years, the utilization of qualified small business stock (“QSBS”) has grown considerably. Many businesses are formed as corporations at conception, private equity investors calculate the tax benefits from Section...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

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

Mayer Brown

Relieved Taxpayers: US Tax Court Reaffirms that IRS Cannot Assess Failure-to-file Penalties

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Every parent remembers when their child learns the meaning of the word “no.” That moment often comes as a shock because, up until that moment, most children are models of obedience and unconditional trust. When children learn...more

McDermott Will & Emery

Weekly IRS Roundup June 10 – June 14, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 10, 2024 – June 14, 2024....more

Foodman CPAs & Advisors

¿Cómo Enmendar Declaración De Impuestos?

El IRS publicó el Consejo Fiscal 2024-38 el 25 de abril de 2024 para explicarle a los contribuyentes cómo enmendar declaración de impuestos. Si un contribuyente descubre un error después de presentar su declaración, es...more

Foodman CPAs & Advisors

How To Amend A Tax Return?

The IRS released Tax Tip 2024-38, April 25, 2024, to explain to taxpayers how to amend a tax return. If a taxpayer discovers an error after filing their return, the taxpayer may need to amend a tax return. IRS states that...more

BakerHostetler

D.C. Court of Appeals Strengthens IRS’ Ability to Collect Penalties for Not Reporting Foreign Company Ownership

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On April 3, 2023, the United States Tax Court issued its opinion in Farhy v. Commissioner of Internal Revenue, which upset long-standing views on how the IRS may assess and collect penalties for failure to file certain tax...more

BakerHostetler

No Further Warnings - Prosecutors Bring First Pure Legal Digital Asset Tax Indictment; More Criminal Cases to Come

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After years of explicitly warning taxpayers that failing to report or underreporting income from transactions involving digital assets would lead to criminal charges, federal prosecutors are now beginning to follow through on...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

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

Holland & Knight LLP

Instructivo declaración impuesto al patrimonio 2023 en Colombia

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Para el diligenciamiento y presentación de su declaración del impuesto al patrimonio del año 2023 en Colombia, sugerimos tener en cuenta las instrucciones que se encuentran en el sistema de la Dirección de Impuestos y Aduanas...more

Freeman Law

Procedimiento simplificado ante el IRS para extranjeros fuera de EUA

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Muchos ciudadanos americanos que viven en el extranjero no presentan su declaración de impuestos en Estados Unidos de América (“EUA”) por diversas cuestiones. Generalmente, esto sucede porque se tiene la creencia que no es...more

Freeman Law

Is a Stiftung a Foreign Trust? Form 3520 Penalties?

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In the recent case of Rost v. United States, the Fifth Circuit analyzed whether a foreign entity should be classified as a foreign trust subject to IRS Form 3520 penalties.  The case arose in the context of a Liechtenstein...more

Freeman Law

How Do I Know if I Have an IRS Form 3520/3520-A Filing Obligation?

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Interests in or transactions with foreign trusts can cause headaches for federal income tax purposes. Depending on the interest or transactions at issue, U.S. citizens or residents may have to file a Form 3520, a Form...more

Dorsey & Whitney LLP

Charitable Contribution and Donor Relation Considerations for 501(c)(3) Organizations

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Donors that make contributions to charitable organizations recognized under Section 501(c)(3) of the Internal Revenue Code of 1986, as amended (the “Code”), may claim an individual income tax deduction under Section 170 (all...more

Opportune LLP

New Mexico Non-Resident Pass-Through Withholding & Composite Return Election

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New Mexico recently enacted legislation qualifying pass-through entities to make an annual election to pay an entity-level state tax for taxable years beginning on or after January 1, 2022. Here’s what it means for your oil...more

Gray Reed

Taxpayer Wins Tax Refund Despite IRS Claims That The Taxpayer Used The Wrong Form

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Dealing with the IRS can be a dangerous labyrinth for the untrained taxpayer or their non-tax advisors. In a recent Federal court case, E. John Rewwer, et al. v. United States, the taxpayers filed the wrong form claiming a...more

Bilzin Sumberg

Emily S. Wilson et al. v. United States: Playing Battleship with the Internal Revenue Service

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As many readers may know, Joseph Wilson (“Mr. Wilson”) was the settlor, tax owner, and beneficiary of a foreign trust. By virtue thereof, Mr. Wilson, as a U.S. citizen, had the requirement to file IRS Form 3520 and IRS Form...more

BCLP

EO Update: e-News for Charities & Nonprofits - July 2021

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Electronic Filing Mandate for Form 990-EZ - The Taxpayer First Act, enacted July 1, 2019, requires tax-exempt organizations to electronically file information returns and related forms. The requirement to file...more

Morgan Lewis

IRS Extends Temporary Use of Electronic and Digital Signatures for Certain IRS Forms Until December 31, 2021

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The US Internal Revenue Service (IRS) extended its temporary approval of accepting digital signatures on certain IRS forms until December 31, 2021 (see Memorandum NHQ-10-1220-000, the Memorandum). This Memorandum has also...more

Morgan Lewis

IRS Approves Temporary Use of Digital Signatures for Certain Forms

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The US Internal Revenue Service (IRS) issued news release IR-2020-194 on August 28, approving the temporary use of digital signatures for certain IRS forms that must be filed with the IRS manually. ...more

Foodman CPAs & Advisors

Treasury and IRS are Aiming to Provide Greater Clarity on International Tax Reporting

On July 14, 2020, the US Treasury Department and the IRS released a proposed redesigned partnership form for tax year 2021 (filing season 2022). The two proposed forms SCHEDULE K-2 (Form 1065) and Schedule K-3 (Form 1065) are...more

Lowndes

Don’t Forget the Tax Man: Many Tax Returns and Payments Due Next Week

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Because of Covid-19, the IRS extended most federal tax filing and payment deadlines otherwise due from April 1, 2020 to July 14, 2020 until July 15, 2020....more

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