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
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
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
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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
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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
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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
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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
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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
