News & Analysis as of

Tax Debt Tax Penalties

Rivkin Radler LLP

Unconstitutionally Excessive FBAR Penalties? It Depends

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You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more

Foodman CPAs & Advisors

Ofrecimiento De Transacción: Oportunidad Para Resolver La Deuda Tributaria

El IRS emitió el Consejo Fiscal 2024-37, el 24 de abril de 2024, para informar a los contribuyentes que no pueden pagar su deuda tributaria completa o si pagar les causaría dificultades financieras, que deberían considerar...more

Foodman CPAs & Advisors

Offer In Compromise: Opportunity To Solve Tax Debt

IRS issued Tax Tip 2024-37, April 24, 2024, to inform taxpayers that can’t pay their full tax debt or if paying would cause financial hardship, that they should consider applying for an offer in compromise which is a program...more

Fox Rothschild LLP

IRS to Focus on High-Income Earners Who Have Not Filed Tax Returns Since 2017

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The IRS expects to send out over 125,000 collection letters to high-income taxpayers who did not file one or more federal income tax returns between 2017 and 2021. As part of the new collection initiative, approximately...more

Jones Day

Brazilian Tax Amnesty Program Temporarily Mitigates Unfavorable Change to Tax Proceedings (UPDATED)

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In Short - The Background: Most Brazilian companies face tax underpayment assessments in light of a complicated tax regime. The Lula government is planning to significantly expand government expenditures and thus needs to...more

Freeman Law

Currently Not Collectible Status

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A topic that doesn’t get a whole lot of attention from tax professionals is “Currently Not Collectible” (“CNC”) status, which is a status that your account with the IRS may obtain when you cannot currently afford to pay the...more

Gray Reed

Compromising with the IRS

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Many people end up owing the IRS for many reasons and there are various options to resolve your tax debt.  Some of the options include an offer in compromise, installment agreement, or currently non-collectible status....more

Freeman Law

A Fresh Start for Taxpayers: The Offer in Compromise

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IRS debt can be a life-changing burden.  But for some taxpayers, an offer in compromise may be an avenue to get rid of that tax debt and to receive a fresh start.  When a taxpayer qualifies for an offer in compromise, the IRS...more

Freeman Law

IRS Seizures: The Good, the Bad, and the Ugly

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Along with tax penalties and tax lien filings, the IRS’s ability to seize a taxpayer’s property is one of its most potent weapons to encourage tax compliance.  That is, in part, what makes a recent report from the Treasury...more

Greenberg Glusker LLP

IRS Issues Notice Providing for the Delay of Federal Tax Filings and Federal Tax Payments

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Although it has occurred sporadically – Notice 20-17 on March 18, Notice 20-18 on March 21, Notice 20-20 on March 27 – the IRS has finally issued comprehensive (almost) guidance in Notice 20-23 on April 9 providing for the...more

Rosenberg Martin Greenberg LLP

Collection: Expatriation with No Tax, Interest or Penalties: New Relief Procedures for Certain Former Citizens

On September 6, 2019, the Internal Revenue Service (IRS) announced the new “Relief Procedures for Certain Former Citizens” (IRS Relief Procedures) who relinquished their United States (U.S.) Citizenship after March 18, 2010....more

Saul Ewing LLP

Illinois Offering Amnesty on Delinquent Tax Debts

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Illinois has enacted the Tax Delinquency Amnesty Act now in effect through November 15, 2019. This is an opportunity for taxpayers with delinquent Illinois taxes to pay the outstanding tax balances, and interest and penalties...more

McDermott Will & Emery

Illinois Amnesty Programs Now Underway

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As previously announced, the Illinois Department of Revenue has begun a new amnesty program, running October 1 through November 15, 2019. All taxes paid to the Illinois Department of Revenue for taxable periods ending after...more

Burr & Forman

South Carolina Tax Penalties

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South Carolina imposes a number of civil tax penalties that are similar to those imposed under the Internal Revenue Code (the “Code”). South Carolina’s civil tax penalties, while similar in some respects, are not the same as...more

Burr & Forman

Appealing A South Carolina State Tax Case: Payment Or Bond?

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Taxpayers who disagree with a proposed tax assessment issued by the South Carolina Department of Revenue (SCDOR or DOR) may or may not be able reach an agreement at the administrative level. When taxpayers and SCDOR cannot...more

Adler Pollock & Sheehan P.C.

Rhode Island Tax Amnesty Soon Available

Rhode Island’s tax amnesty program will open on December 1, 2017, affording taxpayers a rare and limited-time chance to start anew by paying their tax liabilities without penalties and with a 25% reduction in the...more

Burr & Forman

The IRS Has a Lien Against Me: What Do You Do? Tax Lien Release and Discharge (Part 6)

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Where an individual or business owes IRS taxes, Congress has given the IRS a tax lien against all the assets of the taxpayer. The lien covers real estate, homes, furniture, cars, investments, and nearly everything an...more

Burr & Forman

Currently Not Collectible Taxes: What Do You Do? (Part 4)

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If an individual or business owes federal taxes and does not have the current ability to pay these taxes, the IRS can consider placing the account into “currently not collectible” (CNC) status. If placed in CNC status, a...more

Burr & Forman

Tax Payment Plans: What Do You Do? (Part 3)

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If an individual or business owes federal taxes and does not have the current ability to pay these taxes, the IRS can “seller-finance” and offer a payment plan with the taxpayer. The primary benefit of a payment plan is that...more

Dickinson Wright

IRS Tax Penalties

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In a famous saying by Benjamin Franklin, “… but in this world nothing can be said to be certain, except death and taxes.” In the past 100 years, it would be very safe to add to the end of that quote, “and the Internal...more

Burr & Forman

Unfiled Tax Returns: What Do You Do? (Part 2)

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The United States has a voluntary income tax reporting system. U.S. citizens, permanent residents, and businesses here must annually file income tax returns with the IRS, reporting their “worldwide income”, deductions, and...more

Burr & Forman

South Carolina Tax Amnesty for 2017?

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The South Carolina General Assembly approved a law in 2015 allowing the South Carolina Department of Revenue to offer an amnesty program to taxpayers in the state who have not filed tax returns and/or owe state taxes....more

Buchalter

Tax Amnesty Is Back in Arizona

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The State of Arizona’s 2016 amnesty program offers significant benefits to most individuals and corporations with past-due taxes. Once again, Arizona taxpayers with many types of past-due state and local taxes will have...more

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