Nonprofit Quick Tip: State Filings in Kentucky and Tennessee
Our Federal Tax Group explains the new standardized Form 15620 that taxpayers can use when receiving property that is subject to a “substantial risk of forfeiture.”...more
As part of US tax planning for founders, employees, board members, and other individual service providers who receive equity that is subject to vesting in connection with their services, Section 83(b) elections are frequently...more
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
El IRS publicó el Consejo Fiscal 2024-38 el 25 de abril de 2024 para explicarle a los contribuyentes cómo enmendar declaración de impuestos. Si un contribuyente descubre un error después de presentar su declaración, es...more
The IRS released Tax Tip 2024-38, April 25, 2024, to explain to taxpayers how to amend a tax return. If a taxpayer discovers an error after filing their return, the taxpayer may need to amend a tax return. IRS states that...more
After years of explicitly warning taxpayers that failing to report or underreporting income from transactions involving digital assets would lead to criminal charges, federal prosecutors are now beginning to follow through on...more
Are you searching for 2023 tax return preparation and filing tips? The window officially opened to submit 2023 tax returns to the IRS on January 29, 2024. The following day the IRS released IR-2024-38, “Things to remember...more
The Internal Revenue Service (“IRS”) issued an announcement that it is delaying implementation of reporting obligations for businesses that accept large amounts of digital assets. This SKrypto Blog Post summarizes cash and...more
For many organizations and individuals, the end of the calendar year generates significant reporting obligations, particularly with respect to the Internal Revenue Service. The following requirements may not be obvious, but...more
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
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
As part of the 2017 Tax Cuts and Jobs Act (TCJA), Congress modified the rules governing the deductibility of certain government settlement-related expenses under the Internal Revenue Code (IRC). Effective January 1, 2022,...more
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
As part of the 2017 Tax Cuts and Jobs Act (Act), Congress enacted Internal Revenue Code (Code) section 6050X, which requires government agencies (and certain nongovernmental regulatory agencies) to issue information returns...more
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
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
In a previous post, we highlighted guidance released by the IRS on the topic of “relevance” and some of the implications it had in the pre-immigration planning context. More specifically, the guidance addressed issues...more
Dealing with the IRS can be a dangerous labyrinth for the untrained taxpayer or their non-tax advisors. In a recent Federal court case, E. John Rewwer, et al. v. United States, the taxpayers filed the wrong form claiming a...more
As many readers may know, Joseph Wilson (“Mr. Wilson”) was the settlor, tax owner, and beneficiary of a foreign trust. By virtue thereof, Mr. Wilson, as a U.S. citizen, had the requirement to file IRS Form 3520 and IRS Form...more
Canadian persons and entities owning a significant interest in a U.S. corporation or U.S. entity classified as a “disregarded entity” for U.S. federal income tax purposes should ensure they are compliant with IRS Form 5472...more
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
Because of Covid-19, the IRS extended most federal tax filing and payment deadlines otherwise due from April 1, 2020 to July 14, 2020 until July 15, 2020....more
Fax Form 1139 and Form 1045 to Claim Quick Refunds of the Credit for Prior Year Minimum Tax Liability of Corporations and Net Operating Loss Deductions ...more
In an Internal Revenue Service (IRS) interim guidance memorandum authored by Sunita Lough, Deputy Commissioner, Services and Enforcement, the IRS has temporarily approved the acceptance of “signature images” and “digital...more
Seyfarth Synopsis: On March 25, 2020, the Internal Revenue Service (“IRS”) announced its “People First Initiative” (the “Initiative”), which will provide relief to taxpayers by suspending payments under certain collection...more