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
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
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
Blog
Are You an Owner or Beneficiary of a Foreign Trust or Receive a Foreign Gift or Bequest?
The Government is pressing taxpayers with large civil penalties for late-filed Forms 3520. The IRS may assert the penalty in the context... Read More
Blog
Key Moves in Difficult Times -Options for Taxpayers Facing Economic Uncertainty
We are in tough economic times. A record number of Americans have filed for unemployment benefits, and business owners are forecasting a... Read More
Blog
Relief for Taxpayers Affected by Coronavirus Disease 2019 (COVID-19) Pandemic
The recent COVID-19 pandemic has already had a significant effect on our personal and professional lives. Between states and localities implementing “shelter-in-place”... Read More
Blog
Congress Passes New Law, Allows Early Distribution from IRAs for COVID-19
A new law allows individuals under the age of 60 to withdraw up to $100,000 from their IRAs without facing an early... Read More
