News & Analysis as of

Tax Returns Tax Penalties Filing Requirements

Allen Barron, Inc.

The Statute of Limitations for an IRS Audit

Allen Barron, Inc. on

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

BakerHostetler

D.C. Court of Appeals Strengthens IRS’ Ability to Collect Penalties for Not Reporting Foreign Company Ownership

BakerHostetler on

On April 3, 2023, the United States Tax Court issued its opinion in Farhy v. Commissioner of Internal Revenue, which upset long-standing views on how the IRS may assess and collect penalties for failure to file certain tax...more

McDermott Will & Emery

IRS Provides Tax Penalty Relief for Certain Late Filed Returns

McDermott Will & Emery on

In Notice 2022-36, the Internal Revenue Service (IRS) announced relief for taxpayers who failed to file certain tax and information returns with respect to tax years 2019 and 2020. The relief, which will be automatic, is...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

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

IRS Accuracy Related Penalties is the number one most litigated tax issue

The National Taxpayer Advocate 2017 Report to Congress states that the Accuracy-Related Penalty under Internal Revenue Code Section 6662 remains the number one most litigated tax issue and has been over the last four years. ...more

Burr & Forman

IRS Announces End to Foreign Bank Account Disclosure Program: What Can You Do Now If You Still Have Unreported Foreign Bank...

Burr & Forman on

The IRS recently announced it will be shutting down its successful Offshore Voluntary Disclosure Program (OVDP) for unreported foreign bank accounts and income. The program will end September 28, 2018. Under the OVDP, first...more

Burr & Forman

Unfiled Tax Returns: What Do You Do? (Part 2)

Burr & Forman on

The United States has a voluntary income tax reporting system. U.S. citizens, permanent residents, and businesses here must annually file income tax returns with the IRS, reporting their “worldwide income”, deductions, and...more

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