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Farella Braun + Martel LLP

REFRESH: Loot and Private Foundation Rules – Part 2

Welcome to EO Radio Show - Your Nonprofit Legal Resource. In this episode, we refresh EO Radio Show episode 22, the second of our two episodes exploring private foundation rules using commentary on the comic Apple TV+ series...more

Farella Braun + Martel LLP

Nonprofit Quick Tip: State Filings in North Carolina and South Carolina

Welcome to EO Radio Show - Your Nonprofit Legal Resource. Episode 75 is the tenth in a series of Quick Tip episodes focusing on the details of state registration of nonprofit corporations. Today, Cynthia Rowland and Joe...more

Farella Braun + Martel LLP

REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy

Welcome to EO Radio Show - Your Nonprofit Legal Resource. Here we are, solidly in the 2024 election year, and that means that private foundations need to refresh their understanding of election year issues for organizations...more

Farella Braun + Martel LLP

REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Legislative Lobbying and Advocacy...

Welcome to EO Radio Show - Your Nonprofit Legal Resource. As most listeners are undoubtedly aware, 2024 is an election year, and that means that charities and private foundations need to refresh their understanding of...more

Stinson LLP

1099-K Reporting: IRS Further Delays the Day of RecKoning

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In early November, we issued an alert on the filing of information returns by payment settlement entities, such as PayPal or Venmo, when sellers of goods or services use them to carryout payments with buyers (see 1099-K...more

Gray Reed

IRS Concedes Yet Another Form 3520 Related Penalty Case

Gray Reed on

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

Stinson LLP

1099-K Reporting: Is a Day of RecKoning Coming Soon?

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In the American Rescue Plan Act of 2021, Congress lowered the minimum reporting threshold from $20,000 to $600 for filing information returns relating to reportable payment transactions that are facilitated by payment...more

Gray Reed

It’s So Hard to Say Goodbye to USA: Expatriation and the IRS

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Ever thought about packing it all up and starting that romantic, expatriate life abroad? Ever felt like these parts were just so wild, it was time to find yourself a new passport? Expatriation, where a US citizen renounces...more

Allen Barron, Inc.

Part 2 – International Tax Primer for US Taxpayers and Expatriates

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We continue with Part 2 – International Tax Primer for US Taxpayers and Expatriates with one of the most common forms associated with foreign asset and income reporting to the IRS: Form 8938, the Statement of Specified...more

Allen Barron, Inc.

An International Tax Primer for US Taxpayers and Expatriates – Part 1 of 2

Allen Barron, Inc. on

Welcome to part 1 of our Allen Barron International Tax Primer for US Taxpayers and Expatriates. The United States is one of the few countries in the world that taxes its citizens on their worldwide income. US taxpayers are...more

Weber Gallagher Simpson Stapleton Fires &...

2022 Tax Season: What Families Need to Know

As the 2022 tax season kicks off, there are important issues that divorcing parties must consider. First, it is always more beneficial to the family unit for the parties to file taxes married filing jointly. Not only does...more

Freeman Law

Procedimiento simplificado ante el IRS para extranjeros fuera de EUA

Freeman Law on

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

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The Solo 401(k) and Form 5500 trap

I think the Solo 401(k) plan is one of the great treats for sole proprietors. I have been using it for years. The problem is that there is so little help, that sponsors of these plans fall into a trap when they forget that...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?

Freeman Law on

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

Freeman Law

How to Successfully Fight the Section 6721(e) Intentional Disregard Penalty

Freeman Law on

Section 6721 provides the IRS with authority to impose civil penalties against taxpayer-employers who fail to timely file correct information returns (e.g., Forms W-2/W-3 and Forms 940/941). Under section 6721’s three-tiered...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

Sheppard Mullin Richter & Hampton LLP

When Does Cryptocurrency Mining Create a Taxable Event? IRS Does Not Clarify

A couple rejected a refund settlement offer from the IRS over its tax treatment of tokens they earned from mining. Instead, the couple has sought formal adjudication on the issue from the federal courts. The government has...more

Gray Reed

Taxpayer’s Informal Claim for Refund of Taxes Paid and Offset by the IRS Denied on a Technicality

Gray Reed on

Properly navigating the IRS labyrinth of rules and regulations is difficult and sometimes taxpayers fail to dot every “i” and cross every “t”. The results can sometimes be devastating for both individuals and small...more

Dechert LLP

U.S. Treasury Signals that Cryptocurrency Miners & Stakers Will Not Be Subject to Broker Information Reporting Tax Requirements

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On February 11, 2022, in a letter addressed to certain U.S. Senators, the U.S. Department of the Treasury indicated that cryptocurrency miners, cryptocurrency stakers or related hardware or software providers would not be...more

Foodman CPAs & Advisors

How Will Virtual Currency Be Taxed?

Foodman CPAs & Advisors on

Despite the confusing interpretations by US regulators, non-compliance with crypto tax rules can cost taxpayers dearly. Unfortunately, the answer to “how is virtual currency taxed” depends on who you ask....more

Gray Reed

How to Handle IRS Notices and Tax Bills

Gray Reed on

The multiple rounds of stimulus checks as part of the COVID-19 relief legislation may have people believing that mail from the IRS is not always bad news. However, aside from isolated situations, most people still flinch at...more

Foodman CPAs & Advisors

Closing A Foreign Bank Account Will Not Solve A Taxpayer’s Disclosure Problem

IRS is interested in U.S. Taxpayer financial accounts everywhere in the world.  If the IRS learns that a Taxpayer has undisclosed reportable accounts or income before a US Taxpayer reports them, the Taxpayer can face serious...more

Freeman Law

How to Successfully Request IRS Penalty Relief

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Federal tax penalties have always been an IRS priority.  But, perhaps more so today than three decades ago.  For example, in 1987, the IRS reported that it had assessed penalties of approximately $14 billion.  Compare that...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

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