Annual Benefits Forum: How To Be an ERISA Superhero
Labor & Employment Podcast Series, Biden’s First 100 Days: A Check-In for Employers.
Podcast: Texas v. United States of America
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
On July 24, 2024, Normative Instruction No. 2,205/ of the Brazilian Federal Revenue Service (the "Instruction”) was published, that regulates Article 25, paragraph 9-A, and Article 25-A of Decree No. 70,235/1972, establishing...more
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
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
Last April, in Farhy v. Commissioner, the Tax Court held that the IRS did not actually have authority to assess penalties under IRC § 6038. The result was devastating for the IRS, as it meant it did not have authority to...more
In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more
On April 15, the IRS released Notice 2024-33 (the “Notice”), offering limited relief from tax penalties for underpaying estimated income taxes arising from a corporation’s alternative minimum tax (“AMT”). The AMT imposes a...more
Introduction – What Is Tax Penalty Abatement? Audits can be an incredibly frustrating ordeal. From initial contact with tax authorities to digging up old financial records to possibly increasing tax liability, there are...more
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
Over the years, I have observed there is only one thing that a taxpayer fears more than being notified by the IRS that their income tax return for a particular taxable year has been selected for audit, and that is being...more
We once again want to bring to your attention the Internal Revenue Service’s (IRS) new favorite penalty provision: Internal Revenue Code (IRC) Section 6676. We have reported on this provision several times before, but this...more
What is known as the IRS survivor’s penalty, and is there anything that can be done to provide for a surviving spouse as we age? The “survivor’s penalty” is the likelihood that a surviving spouse will face higher federal and...more
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
Within the unpredictable landscape of start-ups and private companies, market volatility can significantly alter a company’s financial trajectory. An integral part of navigating this volatility is understanding the role and...more
The U.S. Department of Labor has published its final rule on how to determine whether a worker is an independent contractor or an employee under the Fair Labor Standards Act (FLSA). The rule is effective March 11, 2024, and...more
On January 9, 2024, the United States Department of Labor (“DOL”) released a final rule (the “Final Rule”) setting forth new standards for determining whether an individual may be classified as an independent contractor under...more
As part of the routine administration of employee benefit plans, shortly after the end of a calendar year, many transactions must be reported to the federal government (“information returns”) and participants (“payee...more
The Internal Revenue Service has announced a new Voluntary Disclosure Program (VDP) that offers businesses a limited-time opportunity to repay improperly claimed Employee Retention Credits (ERC) at a discount while avoiding...more
United States citizens and residents are often not aware of the myriad of foreign information return filing obligations that exist under federal tax laws. For example, buried within the Code are reporting obligations...more
In Lee v. United States, the Federal Court of Appeals for the Eleventh Circuit held that a taxpayer could not avoid late filing and late payment penalties because of the failure of his CPA to electronically file his returns...more
The IRS has placed it’s popular employee retention tax credit program on hold. Claims filed after September 14, 2023 will be placed on hold until at least the end of the year....more
A hearing is scheduled for September 11, 2023 for interested persons and organizations to provide testimony on proposed regulations on the timing and approval process for penalties. Section 6751(b) provides that...more
On August 30, 2023, the federal government formally acknowledged the medical use and low potential of abuse for cannabis, with the US Department of Health and Human Services (HHS) recommending that cannabis be rescheduled to...more
An investment management firm founded and owned by legendary investor (and New York Mets owner) Steve Cohen on August 11 filed a petition in Tax Court contesting an IRS audit adjustment in the amount of $344,063,484 for tax...more
El Consejo de Estado de Colombia en Sentencia de 19 de julio de 2023 (radicado 26209) concluyó que cuando se presenten déficit en las autorretenciones mensuales por impuesto sobre la renta frente al total de ingresos...more