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Tax Liability Internal Revenue Code (IRC) Penalties

Farella Braun + Martel LLP

Insider Transaction Traps for the Unwary

Welcome to EO Radio Show - Your Nonprofit Legal Resource. I'm Cynthia Rowland, and today I'm joined by David Sacarelos, a principal at Baker Tilly. We do a deep dive into the penalties under the Internal Revenue Code sections...more

Rivkin Radler LLP

Observations on Charities, Taxes, and Cash Flow

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Few provisions of the Code have a single, clear meaning that leaves no room for interpretation. Even many of those that, on the surface, appear fairly straightforward, are usually open to alternative “understandings.”...more

Lippes Mathias LLP

Taxpayer Beware: The Pitfalls of Section 965 Installment Payments

Lippes Mathias LLP on

For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...more

Husch Blackwell LLP

Impending IRS Workforce Cuts Mean Taxpayers Should Act Now to Resolve IRS Issues

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The New York Times reported on March 4, 2025, that the Trump administration is aiming to cut half of the Internal Revenue Service’s workforce by the end of the year. The cuts are reportedly across all divisions of the IRS,...more

Proskauer - Tax Talks

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

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On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more

Allen Barron, Inc.

The Taxpayer Bill of Rights - 10 Essential Rights for U.S. Taxpayers

Allen Barron, Inc. on

Are you aware of the Taxpayer Bill of Rights?  We are reminded, especially during tax season, that taxpayers have 10 essential rights when dealing with the Internal Revenue Service. The IRS expects its employees to understand...more

Latham & Watkins LLP

Treasury Finalizes Controversial Regulations on IRS Penalty Oversight, but Debate Continues

Latham & Watkins LLP on

Section 6751(b), designed to ensure supervisory oversight amid rising penalty assertions in settlement negotiations, has been contentious due its ambiguity, and the final regulations may not resolve the debate....more

Bass, Berry & Sims PLC

2025 Changes to ACA Employer Information Reporting Obligations and the Employer Shared Responsibility Penalties

Bass, Berry & Sims PLC on

In December 2024, Congress and President Biden passed two laws—the Paperwork Burden Reduction Act (PBRA) and the Employer Reporting Improvement Act (ERIA)—that made important changes to employers’ responsibilities regarding...more

Ropes & Gray LLP

IRS Issues Final Regulations Requiring Disclosure of Certain “Basis Shifting” Transactions Involving Partnership Distributions and...

Ropes & Gray LLP on

The U.S. Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations on January 14, 2025 (the “Regulations”) requiring taxpayers and their material advisors to disclose...more

Freeman Law

National Taxpayer Advocate’s Annual Report Highlights Issues Plaguing the IRS

Freeman Law on

In her annual report to Congress for 2024, National Taxpayer Advocate (“NTA”) Erin M. Collins identified the processing of Employee Retention Credits (“ERCs”), the administration of civil penalties, and changes to the...more

Kilpatrick

Approaching Deadline: Reporting for ISO Exercises and ESPP Stock Transfers Due Beginning January 31, 2025

Kilpatrick on

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

Cooley LLP

Year-End Reporting for ISO Exercises and ESPP Stock Transfers - January 2025

Cooley LLP on

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

Cole Schotz

RetireReady NJ: Reminder About The Requirements Under The New Jersey Secure Choice Savings Program Act

Cole Schotz on

Employers with at least 25 employees in New Jersey that do not already offer a qualified retirement plan to employees must take action to facilitate the RetireReady NJ Retirement Savings Program (“RetireReady NJ”)....more

Baker Donelson

No More Lists – IRS Concedes on Reportable Transaction Penalties

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Following the 11th Circuit's ruling in Green Rock LLC v. IRS this past summer, the IRS has decided to cease its defense of post-American Jobs Creation Act (AJCA) reportable transaction notices. In an Action on Decision memo...more

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