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Internal Revenue Service Penalties Tax Returns

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.  
Eversheds Sutherland (US) LLP

IRS Removes Willfulness Checkbox from Form 14457, Easing Path for Voluntary Disclosures

In a significant policy shift, the IRS has revised Form 14457, Voluntary Disclosure Practice Preclearance Request and Application, the cornerstone of its Voluntary Disclosure Practice (VDP), by removing the controversial...more

Allen Barron, Inc.

The Risk of California FTB Audits is Increasing

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Did you know that the number of California FTB audits is increasing when compared to the trend of IRS audits in 2025? The California Franchise Tax Board, or FTB, has recently invested in advanced data processing systems and...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

Freeman Law

Tax Cout in Brief | Christiansen v. Commissioner

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The Tax Court in Brief - Freeman Law’s “The Tax Court in Brief” covers substantive Tax Court opinion, providing a brief of its decisions in clear, concise prose....more

Frost Brown Todd

Substantiating the Right to Claim QSBS Tax Benefits | Part 1

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Section 1202 provides an exclusion from capital gains when a stockholder sells qualified small business stock (QSBS), assuming all eligibility requirements are satisfied. Section 1045 provides for the tax-free rollover of...more

Allen Barron, Inc.

You Need an Experienced Tax Attorney when Tax Issues Strike

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Why do you need an experienced tax attorney when tax issues strike? What do you need to know about communications with the IRS and California's tax agencies?...more

Freeman Law

Posts, Profits, & Penalties | Tax Law & Social Media | Part 4

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As discussed in Part 2, there are many ways social media creators earn income. Social media income, like all income, needs to be reported on federal tax returns....more

Womble Bond Dickinson

Micro-Captive Reportable Transaction Deadline Effectively Extended

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On Friday, April 11, 2025, the Internal Revenue Service issued Notice 2025-24 (the “Notice”), which waives applicable penalties under the Internal Revenue Code to participants in, and material advisors to, reportable...more

Jaburg Wilk

Extensions, Amendments and Scams – Three Things to Keep Your Eye on During Tax Season

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As the April 15, 2025 deadline approaches, it’s essential to be prepared for filing your federal tax return. Whether you’re ready to submit your return or need more time, understanding the available options will help ensure a...more

Lippes Mathias LLP

Taxpayer Beware: The Pitfalls of Section 965 Installment Payments

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For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...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

Baker Botts L.L.P. on

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

Freeman Law

Posts, Profits, & Penalties | Tax Law & Social Media | Part 2

Freeman Law on

Cristiano Ronaldo was 2024’s highest-earning Instagram influencer, receiving approximately $3.23 million per post. This jaw-dropping number is not the typical amount that Instagram influencers earn. In fact, on average,...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

Orrick, Herrington & Sutcliffe LLP

Annual Reporting Requirements for Incentive Stock Options and Employee Stock Purchase Plans - January 2025

Annual Information Statements and IRS Returns Requirement to Report For (1) any exercise of an incentive stock option (ISO) during 2024 or (2) transfer during 2024 of a share previously purchased pursuant to a tax-qualified...more

Kilpatrick

Approaching Deadline: Reporting for ISO Exercises and ESPP Stock Transfers Due Beginning January 31, 2025

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This alert is a reminder of the approaching deadlines for certain year-end reporting requirements applicable to corporations that issue stock to employees (including former employees) upon the exercise of certain stock...more

Fenwick & West LLP

IRS Filing and Reporting Requirements for ISO Exercises and ESPP Stock Transfers - January 2025

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The IRS has issued two forms (along with accompanying instructions) that corporations must use to satisfy the return and information statement requirements under Section 6039 of the Internal Revenue Code of 1986, as amended....more

Pillsbury Winthrop Shaw Pittman LLP

Federal and State Tax Relief Resulting from California Fire

The Internal Revenue Service (IRS) has provided broad tax relief to taxpayers in Los Angeles County impacted by the recent winds and wildfires. Other counties may be added later....more

Buchalter

Tax Relief and Recovery: Key Considerations for Los Angeles Residents Affected by Recent Wildfires

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We at the Buchalter law firm understand that many have suffered greatly as a result of the recent wildfires. The loss of life, and the loss of homes with memories is, of course irreplaceable....more

Cooley LLP

Year-End Reporting for ISO Exercises and ESPP Stock Transfers - January 2025

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This alert serves as a reminder of certain year-end reporting requirements imposed under Section 6039 of the Internal Revenue Code of 1986, as amended, with respect to...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

Coblentz Patch Duffy & Bass

IRS Tax Relief for Southern California Wildfire Victims

In light of the ongoing wildfires in Los Angeles, we want to take a moment to express our deep concern for all those affected by this devastating disaster. Our thoughts are with everyone impacted by the fires....more

Seward & Kissel LLP

IRS Proposes Regulations Regarding Tax Treatment of Certain Basket Option Contracts and Basket Contracts

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Last week, the Internal Revenue Service (“IRS”) proposed regulations (the “Proposed Regulations”) to treat certain basket contracts as listed transactions. Basket contracts were previously identified as transactions of...more

Allen Barron, Inc.

How Does the IRS Define Willfulness in Unreported or Under-reported Offshore Income

Allen Barron, Inc. on

How does the IRS define willfulness in unreported or under-reported offshore income?  What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct?  Why should U.S. taxpayers be...more

McDermott Will & Emery

Weekly IRS Roundup June 10 – June 14, 2024

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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

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