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
COVID-19 Update
Due to the COVID-19 pandemic, the firm is currently not scheduling any in-person events or speaking engagements. Please watch for updates regarding... Read More
Blog
District Court Lowers Penalties for Form 3520 Nonfiling to Zero
A recent taxpayer-friendly court decision from New York is worth reviewing for practitioners who handle late-filed Forms 3520, Annual Return to Report... Read More
Blog
Do You Own a Foreign Corporation? IRS Presses Form 5471 Penalties
The San Francisco Bay Area is a focal point for international business. It is common for individuals to start a business, and... Read More
