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Tax Liability Filing Requirements Tax Planning

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

Gray Reed

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

Gray Reed on

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

Allen Barron, Inc. on

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

Freeman Law

Is a Stiftung a Foreign Trust? Form 3520 Penalties?

Freeman Law on

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?

Freeman Law on

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

Dechert LLP

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

Dechert LLP on

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

Freeman Law on

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

Foodman CPAs & Advisors

How does IRS Identify Cases with Audit Potential?

Understanding how the IRS identifies cases that have audit potential can be learned from the CONGRESS OF THE UNITED STATES (CONGRESSIONAL BUDGET OFFICE) Report released on July, 2020: Trends in the Internal Revenue Service’s...more

Foodman CPAs & Advisors

What happens when Taxpayers try to tell the IRS that it is not “Mea Culpa”?

According to the IRS Manual, reasonable cause for abating penalties is based on all the facts and circumstances of a Taxpayer’s situation.  IRS will consider reasons which establish that a Taxpayer used all ordinary care and...more

Foodman CPAs & Advisors

So much of Virtual Currency is still subject to Interpretation

On February 12,2020, the U.S. Government Accountability Office (GAO) published a Report  on Virtual Currencies which discusses whether Taxpayers  who use Virtual Currency (VC) are fully meeting their tax obligations.  ...more

Foodman CPAs & Advisors

Were you Engaged in Virtual Currency transactions in 2019?

In 2019, taxpayers who engaged in a transaction involving virtual currency will need to file Schedule 1, Additional Income and Adjustments to Income.  Schedule 1 of the 2019 1040 Form presents the question to Taxpayers...more

Seyfarth Shaw LLP

Due Date for Paying Certain Federal Income Taxes Deferred Until July 15, 2020

Seyfarth Shaw LLP on

Seyfarth Synopsis: To provide relief to taxpayers affected by the 2019 Novel Coronavirus disease (“COVID-19”), the U.S. Treasury Department and Internal Revenue Service deferred the April 15, 2020 due date for paying certain...more

Seyfarth Shaw LLP

Fix a Decade of Document Errors? Yes You Can!

Seyfarth Shaw LLP on

Seyfarth Synopsis: In two months (on March 31, 2020), the window closes for 403(b) plan sponsors to take advantage of the unique opportunity to retroactively amend their 403(b) retirement plans to correct document errors...more

Foodman CPAs & Advisors

IRS issues FATCA Relief but not for All

On September 6, 2019, IRS announced Relief Procedures for Certain Former Citizens.  These are procedures for certain persons who have relinquished, or intend to relinquish, their United States  citizenship, who wish to come...more

Kramer Levin Naftalis & Frankel LLP

Virtual Currency

On Oct. 9, 2019, the Internal Revenue Service (the “Service”) issued Revenue Ruling 2019-24 concerning the tax consequences of virtual currency hard forks, as well as FAQs on the taxation of virtual currency generally. This...more

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