The California Franchise Tax Board Extends Deadline to Participate in Resolution Program Targeting Certain Microcaptive Insurance Arrangements and Syndicated Conservation Easements
The FTB just extended the deadline to participate in its resolution program until January 31, 2024.[1] Previously, the FTB sent letters to... Read More
Form 3520 Foreign Trust Reporting for Tax Counsel: Filing Requirements and Penalty Abatements for Delinquencies
We are pleased to announce that Steven L. Walker will be speaking at the upcoming Strafford webinar, “Form 3520 Foreign Trust Reporting... Read More
Employee Retention Credit -IRS Stops Processing New Claims – Fraud
The IRS is cracking down on promoters and others who are filing questionable claims for Employee Retention Credit. For those individuals who... Read More
The Federal Tax Lien and Exemptions: Handling IRS Enforcement of Valid Tax Liens
This article provides advice for guiding clients that seek to discharge taxes in bankruptcy and practical guidance to help avoid common pitfalls... Read More
Consequences of Failing to Report Federal Changes to the California FTB or Filing State Returns
On Oct. 14, 2021, the Ninth Circuit Court of Appeals in Berkovich affirmed the decision from the Bankruptcy Appellate Panel (BAP) that because a... Read More
Staying IRS Enforced Collection Action Through Bankruptcy
An advantage of filing bankruptcy is that it can stop certain collection actions by the IRS. For example, suppose that a taxpayer... Read More
Reduction of Tax Attributes under I.R.C. § 108(b)
A taxpayer does not always get to eat cake and keep it too. When discharge of indebtedness (other than real property business... Read More
Taxation of the Bankruptcy Estate
The taxation of the bankruptcy state is not always obvious, and below are the key highlights for debtors to keep in mind. ... Read More
Handling Audits of Delinquent International Information Returns
This article examines strategies for handling an IRS investigation of international returns, and recommends ways to improve audits, foster taxpayer compliance, and... Read More
Blog
IRS Provides Temporary Relief for Taxpayers in Audits and Collections – Certain Activities Continue
On March 25, 2020, the Internal Revenue Service issued a news release announcing the People First Initiative. See IR-2020-59 (03-25-2020). The new... Read More
