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Wiley Rein LLP

The Laws About Lobbying for or Against Nominees for the New Administration

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President-Elect Trump’s potential nominees for the Cabinet and other high-level offices in his second Administration have been at the top of the news for the past several weeks. You, your company, your trade association, your...more

Holland & Hart LLP

the buzz: Cannabis News & Policy Update - December 2024

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Welcome back to the buzz, our monthly cannabis news and policy update. Your at-a-glance source for regulatory developments, agency announcements, and trends impacting the cannabis industry. In this edition of the buzz,...more

Mayer Brown

Relieved Taxpayers: US Tax Court Reaffirms that IRS Cannot Assess Failure-to-file Penalties

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Every parent remembers when their child learns the meaning of the word “no.” That moment often comes as a shock because, up until that moment, most children are models of obedience and unconditional trust. When children learn...more

J.S. Held

How to Defend Against Identity Theft This Tax Season

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In recent years, identity theft cases have surged, especially during tax season. According to the Internal Revenue Service (IRS), in 2022, the federal agency identified and prevented USD 5.7 billion in tax-related fraud, and...more

Stinson LLP

1099-K Reporting: More Time to Transition to the $600 Reporting Threshold

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In the American Rescue Plan Act of 2021, Congress and the Biden administration lowered the minimum reporting threshold for filing information returns relating to “reportable payment transactions” (a payment card is accepted...more

Foodman CPAs & Advisors

Forms 3520 and 3520-A Late Filing get IRS Relief

On 10/24/24, the National Taxpayer Advocate shared on its NTA Blog that the IRS has discontinued its policy of automatically imposing penalties for late submissions of Form 3520, which pertains to foreign gifts and...more

McDermott Will & Emery

Weekly IRS Roundup November 18 – November 22, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 18, 2024 – November 22, 2024. ...more

Rodemer Kane Attorneys at Law

Tax Fraud: Simple Mistake or Serious Crime?

Taxes. Except for maybe the CPAs and tax professionals, the word alone elicits groans and sighs from even the most cheerful among us. While the necessity of taxes is rarely disputed, navigating the complex world of tax...more

Kilpatrick

New Form Section 83(b) Election Released by IRS

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On November 7, 2024, the IRS released Form 15620, which can be used by taxpayers to file Section 83(b) elections in connection with transfers of property that are subject to a substantial risk of forfeiture when transferred...more

Allen Barron, Inc.

What is Willful Blindness According to the IRS?

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What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an...more

Snell & Wilmer

IRS Releases Standardized Section 83(b) Election

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As explained in a prior blog post, an employee who timely files a Section 83(b) election will be taxed on the fair market value of property transferred (typically restricted stock) to him or her in exchange for services on...more

A&O Shearman

IRS creates a standardized Section 83(b) Election form

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On November 7, 2024, the U.S. Internal Revenue Service (the IRS) released Form 15620,1 which standardizes elections under section 83(b) of the Internal Revenue Code of 1986, as amended (the “Code,” and such elections,...more

Farrell Fritz, P.C.

Third-Party Contacts and the Need for Taxpayer Protection

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Taxpayers are required to maintain records in sufficient detail to enable the preparation of an accurate tax return. Thus, in the context of an examination, the Internal Revenue Service (“IRS”) has broad authority to examine...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XIII – What...

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Basic Rules - IRC § 6501(a) generally requires the IRS to assess tax within three (3) years after a tax return is filed by the taxpayer. There are two (2) notable exceptions to this rule under IRC § 6501(c) and (e),...more

Stinson - Benefits Notes Blog

IRS Introduces Official Section 83(b) Election Form

On November 7, 2024, the IRS introduced Form 15620, a new standardized form for taxpayers opting to make a Section 83(b) election. Previously, taxpayers needed to send a letter to the IRS with the required information to make...more

Gray Reed

News Flash: Tax Fraud by Ex Causes One Woman Lingering Heartache

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In recent headlines, an Ohio woman has brought a refund suit in district court, seeking recovery of taxes and withholding from the IRS that she claims were based on the improper return filed by her abusive ex-boyfriend. The...more

Miller Canfield

Getting an Erroneous Tax Refund Case to a Jury is a Fraught Task in the Fifth Circuit

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In Grigsby v. United States, the Justice Department used discovery procedures in federal district court essentially to audit a taxpayer’s federal income tax credits for research activities. The court found that the taxpayer...more

McDermott Will & Emery

Weekly IRS Roundup October 28 – November 1, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 28, 2024 – November 1, 2024....more

Rivkin Radler LLP

Challenge to Collection Due Process? Will Supreme Court Affirm IRS’s Offset of Valid Refund With Disputed Tax Liability?

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Earlier this year the IRS announced that, as part of its larger compliance efforts begun last fall under the Inflation Reduction Act, the agency’s stepped-up enforcement activity with respect to high wealth, high income...more

McDermott Will & Emery

Weekly IRS Roundup October 7 – October 11, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 7, 2024 – October 11, 2024. ...more

BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: U.S. Tax Reporting for Americans That Live Overseas and Voluntary...

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Americans who live abroad continue to be subject to U.S. taxation despite having left the United States. American expats should be aware of this and the consequences of not being tax compliant. George McCormick discusses...more

Vinson & Elkins LLP

Crux + Vinson & Elkins: Tax Credit Transfers 101: A Guide to the Essential Steps

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Much has been written about the benefits of tax credit transfers following the passage of the Inflation Reduction Act (IRA), but questions remain as to how to actually effectuate a transfer. This how-to guide provides market...more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30, 2024 – October 4, 2024....more

Bradley Arant Boult Cummings LLP

IRS Announces Broad Filing and Payment Extensions to Hurricane Victims; Alabama DOR Offers “Case-by-Case” Relief | Insights &...

On October 1, the Internal Revenue Service (IRS) issued a sweeping notice regarding Hurricane Helene relief. The disaster tax relief covers all individuals and businesses affected by Hurricane Helene, “including the entire...more

Allen Barron, Inc.

The Statute of Limitations for an IRS Audit

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What is the statute of limitations for an IRS audit? What rules extend the window for an IRS audit? How long does the IRS usually have to complete an audit of your taxes? Everyone may have a little fear in the back of...more

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