News & Analysis as of

Penalties Internal Revenue Service

Seward & Kissel LLP

IRS Proposes Regulations Regarding Tax Treatment of Certain Basket Option Contracts and Basket Contracts

Seward & Kissel LLP on

Last week, the Internal Revenue Service (“IRS”) proposed regulations (the “Proposed Regulations”) to treat certain basket contracts as listed transactions. Basket contracts were previously identified as transactions of...more

Vinson & Elkins LLP

The Very Timely PWA Requirements Finalized

Vinson & Elkins LLP on

On June 18, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued final regulations (T.D. 9998) (the “Final Regulations”) regarding compliance with the prevailing wage...more

Allen Barron, Inc.

How Does the IRS Define Willfulness in Unreported or Under-reported Offshore Income

Allen Barron, Inc. on

How does the IRS define willfulness in unreported or under-reported offshore income?  What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct?  Why should U.S. taxpayers be...more

Kohrman Jackson & Krantz LLP

IRS Extends Pause on RMD Penalties for Inherited IRAs

Hard-working Americans spend a lifetime trying to obtain financial stability and to then provide a financial legacy for their families. Often, the strategy to achieve such goals involves the funding of individual retirement...more

McDermott Will & Emery

Weekly IRS Roundup June 10 – June 14, 2024

McDermott Will & Emery on

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

Allen Barron, Inc.

Are you Thinking of Moving to Another Country - A Few Things to Consider

Allen Barron, Inc. on

Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more

Foley & Lardner LLP

Five Things on the Department of Labor’s Radar for Employee Benefit Plans

Foley & Lardner LLP on

All qualified retirement plans are subject to a myriad of requirements of the Employee Retirement Income Security Act of 1974, as amended (ERISA). The United States Department of Labor (DOL) is charged with enforcing the...more

Allen Barron, Inc.

Questions Regarding Offshore Accounts and FBAR Filing Requirements

Allen Barron, Inc. on

Many US taxpayers still have questions regarding offshore accounts and FBAR filing requirements and compliance. Is there a genuine risk their activities (or lack of compliance) will come to light? The definition of a US...more

Allen Barron, Inc.

The Risks of an IRS Quiet Disclosure

Allen Barron, Inc. on

What are the risks of an IRS quiet disclosure? Is there a formal IRS process known as a "quiet disclosure," and does the IRS honor this strategy for amended tax returns?...more

Snell & Wilmer

Department of Justice Announces Groundbreaking Whistleblower Program in its Ongoing Effort to Incentivize Voluntary Self...

Snell & Wilmer on

Department of Justice (DOJ) Deputy Attorney General Lisa Monaco announced that the DOJ is adopting a whistleblower incentive program today at the American Bar Association’s 39th National Institute on White Collar Crime. In...more

Foley & Lardner LLP

What Every Multinational Company Should Know About … Antiboycott Regulations

Foley & Lardner LLP on

During the mid-1970’s, the U.S. adopted two laws that seek to counteract the participation of U.S. citizens in other nations’ economic boycotts or embargoes. These antiboycott laws are the 1977 amendments to the Export...more

Allen Barron, Inc.

When is a US Taxpayer Required to Disclose Offshore Accounts on an FBAR and Form 8938

Allen Barron, Inc. on

When is a US Taxpayer required to disclose offshore accounts on an FBAR and IRS Form 8938? While many US taxpayers and expatriates have come to understand the requirements of the FinCEN Form 114 or FBAR, a surprising number...more

Allen Barron, Inc.

What Happens If You Don't File an FBAR

Allen Barron, Inc. on

It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US,...more

ArentFox Schiff

Staying on Course: Navigating Election Year Issues for Exempt Organizations

ArentFox Schiff on

With the 2024 election cycle underway, it is important for exempt organizations to understand and comply with relevant restrictions on political campaign activities to safeguard their tax-exempt status and avoid triggering...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Long Awaited Elective Payment Election Final Regulations and Other Guidance Issued by Treasury Department and IRS

On March 5, 2024, the U.S. Department of Treasury and Internal Revenue Services (IRS) released final regulations regarding the direct payment election under the Inflation Reduction Act of 2022 (IRA), a tax credit monetization...more

Allen Barron, Inc.

Have You Disclosed Offshore Cryptocurrency and NFT Activities to the IRS?

Allen Barron, Inc. on

Have you fully disclosed offshore cryptocurrency and NFT activities to the IRS? Earlier this month, the US Department of Justice announced the indictment of a Texas man for tax returns that were inaccurate, incomplete, or...more

Allen Barron, Inc.

What is the IRS Offshore Voluntary Disclosure Program?

Allen Barron, Inc. on

What is the IRS Offshore Voluntary Disclosure Program and who is it designed to help? What are the guidelines for voluntary disclosure to the IRS and who is eligible to apply? The IRS Offshore Voluntary Disclosure...more

Snell & Wilmer

Certain Information Statements for ISOs and ESPPs Due by January 31, 2024

Snell & Wilmer on

As reported in Part 4 of our 2022 End of Year Plan Sponsor “To Do” List, Section 6039 of the Internal Revenue Code (the “Code”) requires employers to provide a written information statement to each employee or former...more

Mintz - Employment Viewpoints

Corporations with 10 or More ISO or ESPP Reporting Obligations on Forms 3921 or 3922 Should Take Notice of Revised Electronic...

Each year, corporations that have employees who exercise incentive stock options (ISOs) as described under Section 422(b) of the Internal Revenue Code must file a Form 3921 with the IRS for each transfer of stock to those...more

Foodman CPAs & Advisors

Avisos De Cobros Del IRS Se Reiniciarán En 2024

Avisos de Cobros del IRS se reiniciarán en 2024 así como un nuevo alivio de multas para aproximadamente 4.7 millones de personas, empresas y organizaciones exentas de impuestos a las que no se les envió un recordatorio...more

Foodman CPAs & Advisors

IRS Collection Notices To Re-Start In 2024

On 12/19/23, the IRS announced the restart of IRS collection notices as well as a new penalty relief for approximately 4.7 million individuals, businesses and tax-exempt organizations that were not sent an automated IRS...more

Jackson Walker

IRS Announces Voluntary Disclosure Program for Employee Retention Tax Credits

Jackson Walker on

On December 21, 2023, the Internal Revenue Service (IRS) issued Announcement 2024-3, setting forth the parameters of a voluntary disclosure program (the “Program”) for taxpayers to resolve Employee Retention Tax Credit (ERTC)...more

Latham & Watkins LLP

Reminder: Employers Must Report 2023 ISO and ESPP Transactions

Latham & Watkins LLP on

Deadlines are approaching for employers to report employee exercises of incentive stock options and employee stock purchase plan purchases during 2023. Corporations that offer incentive stock options (ISOs) or maintain a...more

Rumberger | Kirk

Protecting Your Business From Widespread ERC Scams

Rumberger | Kirk on

Misinformation and widespread scams have created pitfalls for businesses regarding the employee retention credit - The Employee Retention Credit (ERC) has been one of the most discussed tax topics of 2023. Although...more

Allen Barron, Inc.

Are There Strategies to Avoid an IRS Audit?

Allen Barron, Inc. on

Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more

192 Results
 / 
View per page
Page: of 8

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide