News & Analysis as of

Penalties Internal Revenue Service Filing Requirements

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

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

BakerHostetler

Per-Account or Per-Form Penalty?

BakerHostetler on

Key Takeaways: ..The law regarding computation of FBAR penalties is unclear. ..The United States Supreme Court has agreed to hear a case to settle a conflict among the circuit courts. ..Until the Supreme Court...more

Alston & Bird

Back to School: FBAR Penalties and a Lesson in Statutory Construction

Alston & Bird on

Every U.S. person who has a financial interest in, or signature authority over, any foreign financial accounts (including bank accounts, securities, or other types of financial accounts located outside of the U.S.) must file...more

Foodman CPAs & Advisors

Not Mea Culpa

There are times when Taxpayers will attempt to use the “it is not my fault” argument as a defense relating to IRS penalties. Taxpayers might argue that they relied on guidance from a tax professional or from a tax software...more

Farella Braun + Martel LLP

Form 990 Processing Changes – Nonprofit Filers Beware!

The May 15, 2018 filing due date for the Form 990 for tax-exempt organizations operating on a calendar year is just around the corner. Organizations may file Form 8868, Application for Automatic Extension of Time to File an...more

Perkins Coie

Employer Shared Responsibility: Have Penalties Been—or Will Penalties Ever Be—Assessed?

Perkins Coie on

Are you an Applicable Large Employer (ALE) that has received rejected Forms 1095-C from the IRS? If so, you are not alone. ...more

Foodman CPAs & Advisors

IRS will not Quit

Voluntary compliance is the foundation of our US tax system. Taxpayers determine the correct amount of their tax and complete appropriate returns, rather than the Government determine their tax for them. According to the...more

Farrell Fritz, P.C.

Reporting A Closely Held U.S. Corporation’s Overseas Activities

Farrell Fritz, P.C. on

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

Goulston & Storrs PC

New Trade Act Hikes Penalties for Information Return Failures

Goulston & Storrs PC on

The newly-enacted Trade Preference Extension Act boosts the penalties for failing to provide accurate information returns to the IRS and payees – such as Forms W-2, 1098, and 1099, as well as Forms 1095-B and 1094-B. The...more

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