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Internal Revenue Service Compliance Penalties

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Oberheiden P.C.

5 Key Considerations for Defending Against Low Income Housing Tax Credit (LIHTC) Fraud Allegations

Oberheiden P.C. on

Over its nearly 40-year history, the federal low income housing tax credit (LIHTC) program has been both a success story and a target for various forms of fraud. The LIHTC program has been credited with facilitating the...more

White & Case LLP

Tax-Exempt Organizations Should Prepare Now For An IRS Tax Audit

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It is an uncertain time to be a tax-exempt public charity or private foundation. The federal government has recently scrutinized certain tax-exempt organizations (see here), and draft congressional legislation proposed a tax...more

Cadwalader, Wickersham & Taft LLP

Comments Would Limit Circular 230 Proposed Regulations

On December 26, 2024, the IRS published proposed regulations on Circular 230, which governs the conduct of practitioners who practice before the IRS. The New York State Bar Association Tax Section (NYSBA) has submitted...more

Baker Botts L.L.P.

Taxpayer Assistance and Service Act – Tax Controversy Perspective

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On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a legislative proposal that, if passed, could significantly alter tax controversy...more

Proskauer - Tax Talks

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

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On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more

Allen Barron, Inc.

International Business and Offshore Investment and Banking Create Genuine IRS Risk

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International business and offshore investment and banking create genuine risk and exposure with the IRS. This extends to real estate ownership outside of the U.S. and other offshore-related financial activities, which raise...more

Offit Kurman

Not Realizing the True Value of “Stuff”

Offit Kurman on

For federal estate and gift tax purposes, transfers are valued at the “fair market value” of the asset on the date of transfer. One of the more common estate tax audit issues is the failure to properly report the value of...more

Mitratech Holdings, Inc

ACA Reporting Deadlines for 2025: What You Need to Know

Understanding reporting rules for the Affordable Care Act (ACA) is more than a best practice. It’s a legal imperative. If your reports aren’t timely and accurate, you face penalties....more

Bass, Berry & Sims PLC

2025 Changes to ACA Employer Information Reporting Obligations and the Employer Shared Responsibility Penalties

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In December 2024, Congress and President Biden passed two laws—the Paperwork Burden Reduction Act (PBRA) and the Employer Reporting Improvement Act (ERIA)—that made important changes to employers’ responsibilities regarding...more

Faegre Drinker Biddle & Reath LLP

Affordable Care Act Penalty and Reporting Relief

The Employer Reporting Improvement Act and the Paperwork Burden Reduction Act (PBA), each signed into law in December 2024, provide the following penalty and reporting relief for plan sponsors required to provide minimum...more

Ropes & Gray LLP

IRS Issues Final Regulations Requiring Disclosure of Certain “Basis Shifting” Transactions Involving Partnership Distributions and...

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The U.S. Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations on January 14, 2025 (the “Regulations”) requiring taxpayers and their material advisors to disclose...more

Goodwin

Deadline Approaching for Reporting 2024 ISO Exercises and ESPP Share Transfers

Goodwin on

The Internal Revenue Code requires corporations to provide information statements to employees (including former employees) and information filings to the IRS regarding exercises of incentive stock options (ISOs) by employees...more

Cole Schotz

RetireReady NJ: Reminder About The Requirements Under The New Jersey Secure Choice Savings Program Act

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Employers with at least 25 employees in New Jersey that do not already offer a qualified retirement plan to employees must take action to facilitate the RetireReady NJ Retirement Savings Program (“RetireReady NJ”)....more

Vinson & Elkins LLP

Treasury and IRS Finalize Disclosure Requirements for So-Called Related-Party “Basis-Shifting” Transactions

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The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”...more

Baker Donelson

No More Lists – IRS Concedes on Reportable Transaction Penalties

Baker Donelson on

Following the 11th Circuit's ruling in Green Rock LLC v. IRS this past summer, the IRS has decided to cease its defense of post-American Jobs Creation Act (AJCA) reportable transaction notices. In an Action on Decision memo...more

Holland & Knight LLP

Final Regulations Issued on Penalty Supervisory Approval

Holland & Knight LLP on

More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more

Latham & Watkins LLP

Reminder: Employers Must Report 2024 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 2024. Corporations that offer incentive stock options (ISOs) or maintain a...more

Venable LLP

Changes to the ACA: Reporting and Employer Penalties

Venable LLP on

President Biden recently signed into law the Paperwork Burden Reduction Act and the Employer Reporting Improvement Act. These new laws make important changes to the Affordable Care Act (ACA)....more

Allen Barron, Inc.

Is it Too Late to Correct Past FBARs and File Amended Returns with the IRS?

Allen Barron, Inc. on

Is it too late to correct past FBARs and file amended returns with the IRS? The net is closing in on U.S. taxpayers with unreported or under-reported domestic and offshore income and assets. The IRS has increased audits in...more

Snell & Wilmer

2024 End-of-Year Plan Sponsor “To Do” List (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 SW Benefits Updates. This Part 1 covers year-end health and welfare plan issues. Parts 2,...more

Oberheiden P.C.

5 IRS Penalty Abatement Strategies

Oberheiden P.C. on

As a U.S. taxpayer, one of the last things that you want to hear is that the Internal Revenue Service (IRS) has disagreed with your tax assessment and has imposed penalties for noncompliance. The good news is that the IRS...more

Guidepost Solutions LLC

Monitoring Against Whistleblower Retaliation

Guidepost Solutions LLC on

Saves Lives, Prevents Major Crimes, and Accelerates Voluntary Self - Disclosures The U.S. Department of Justice (“DoJ”) recently spotlighted its Whistleblower Awards Program and Voluntary Self Disclosure (“VSDs”)...more

Allen Barron, Inc.

IRS Revisions to the Voluntary Disclosure Program for 2024

Allen Barron, Inc. on

What are the IRS revisions to the Voluntary Disclosure Program for 2024? The foundation of the current IRS Voluntary Disclosure Program (VDP) goes as far back as 2009 when the agency worked to provide U.S. taxpayers with a...more

Latham & Watkins LLP

Reminder: Employers Must Report 2023 ISO and ESPP Transactions

Latham & Watkins LLP on

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

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