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Penalties Internal Revenue Service Reporting Requirements

Vinson & Elkins LLP

The Very Timely PWA Requirements Finalized

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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

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

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

Foley & Lardner LLP

What Every Multinational Company Should Know About … Antiboycott Regulations

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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

Latham & Watkins LLP

Reminder: Employers Must Report 2023 ISO and ESPP Transactions

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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

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

Downs Rachlin Martin PLLC

Corporate Transparency Act Imposes New Federal Reporting Requirement On Businesses

Background - In January 2021, the United States Congress passed the Corporate Transparency Act (CTA) as part of the Anti-Money Laundering Act of 2020. This law, while intended to prevent criminal actors from hiding and...more

Snell & Wilmer

2023 End-of-Year Plan Sponsor “To Do” Lists (Part 1) Health and Welfare

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We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

Gray Reed

FBAR Penalty Defenses and Techniques: The Wrong “Willful” Penalty Computation

Gray Reed on

On September 8, 2023, the IRS issued a News Release suggesting that FBAR compliance investigations and audits would heat up in the near future.  For those unfamiliar with FBARs, federal law requires United States persons to...more

Trusaic

Breaking Down ACA Penalty Letters: IRS’s 2021 Initiative

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The IRS has issued its first ACA penalty letters for tax year 2021. While employers have been forewarned, many may not be fully armed to respond in a timely and compliant manner. The IRS is making good on its promise, and...more

Keating Muething & Klekamp PLL

Benefits Monthly Minute - March 2023

The March Monthly Minute highlights new proposed deadlines for use of retirement plan forfeitures, unsuccessful efforts to overturn the final ESG rule, and ACA penalty increases for 2024. Sorry Not Sorry: Biden Vetoes...more

BakerHostetler

Supreme Court Rules in Favor of Taxpayer in FBAR Case Penalty for Non-Willful Violations Apply on a Per-Report Basis

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On Feb. 28, the U.S. Supreme Court ruled that non-willful penalties related to FBARs apply to each report filed, not on a per-account basis. The 5-4 decision resolved a split between the Fifth and Ninth circuits that focused...more

Fuerst Ittleman David & Joseph

FinCEN Issues Final Rule for Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act

On September 29, 2022, the Financial Crimes Enforcement Network (“FinCEN”) promulgated its much-anticipated Final Rule implementing the beneficial ownership reporting scheme mandated by the Corporate Transparency Act....more

Holland & Knight LLP

Willful or Non-Willful? That Is the Question: IRS Rejects Non-Willful Certification

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In Flint v. United States, 2022 WL 3593826 (Fed. Cl. 2022), the court held that the executors of an estate could not recover a six-figure "Title 26 miscellaneous offshore penalty" (MOP) the decedent paid to the Internal...more

Freeman Law

A Current “Playoff Picture” of Non-Willful FBAR Violations

Freeman Law on

It’s that time of year again. Various football teams scramble at the end of the regular season for a chance at the playoffs. And with each game’s conclusion spectators get an updated “playoff picture” with respect to where...more

Freeman Law

Do FBAR Penalties Survive Death? A Texas Court Says “Yes”

Freeman Law on

A federal district court in Texas recently took up an interesting FBAR issue: whether civil FBAR penalties survive death?  That is, if a taxpayer/account holder dies after the IRS assesses an FBAR penalty against them, do the...more

Bracewell LLP

2020 Incentive Stock Option & Employee Stock Purchase Plan Reporting

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Now that 2021 is here, corporations should be aware of IRS reporting requirements regarding certain 2020 stock transactions with their employees. Section 6039 of the Internal Revenue Code of 1986, as amended (the...more

McAfee & Taft

IRS announces relief for certain Form 1094/1095 reporting requirements

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In a similar move as in previous years, the IRS has issued relief from certain Form 1094-C and 1095-C reporting requirements under the Affordable Care Act relating to employee health plans, as well as relief from certain...more

Burr & Forman

Ho, Ho, Ho, ACA Reporting Relief Five Years in a Row

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Since 2015, employers and health insurers have been required to report health plan coverage information to the IRS and to individuals. Why? The information is necessary in order for the IRS to administer certain portions of...more

Bricker Graydon LLP

ACA update: Form 1095-C deadline extended and other relief

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You’ve been at this Affordable Care Act reporting for years and are cruising on autopilot, right? Regardless of your confidence level, all employers need to note the extended due date for furnishing Form 1095-C to individuals...more

Ballard Spahr LLP

A Little Extra: IRS Ups ACA Reporting Relief

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Once again, the IRS has extended the deadline for furnishing Forms 1095-B and 1095-C to individuals. Reporting penalties will not apply to those who meet the applicable deadlines and complete the forms in good faith....more

Blank Rome LLP

IRS Issues Notice Reminding Businesses of the Obligation to Report “Cash” Transactions over $10,000

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Businesses whose customers purchase over $10,000 worth of goods and services in cash (including cashier’s checks, bank drafts, and money orders) must report these transactions to the Internal Revenue Service (“IRS”)....more

Carlton Fields

Developing a Strategy to Fight FBAR Penalties

Carlton Fields on

Since 2009, the number of FBAR penalties imposed for failures to report foreign bank accounts and the size of the penalties have both increased dramatically. Originally published in The Tax Advisor....more

Baker Donelson

Executive Order Results in IRS' Reconsideration of Plan to Reject Certain Returns Missing Health Insurance Information

Baker Donelson on

The IRS recently announced that it will not automatically reject individual income tax returns on which a taxpayer has failed to indicate whether they maintained qualifying health insurance coverage during the year for the...more

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