Insights

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 initiative is aimed at helping taxpayers by providing relief on a variety of issues ranging from easing payment

A recent taxpayer-friendly court decision from New York is worth reviewing for practitioners who handle late-filed Forms 3520, Annual Return to Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, for offshore trusts. The federal district court struck

The San Francisco Bay Area is a focal point for international business. It is common for individuals to start a business, and later expand operations overseas to Europe or Asia.  There is no prohibition in expanding overseas, but U.S. persons

The Government is pressing taxpayers with large civil penalties for late-filed Forms 3520.  The IRS may assert the penalty in the context of a foreign trust or if you are a U.S. person who received foreign gifts of money or

We are in tough economic times.  A record number of Americans have filed for unemployment benefits, and business owners are forecasting a significant drop in profits, as they seek to cut costs and penny-pinch to make it through the year.

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” orders, commercial activity grinding to a near halt, and the stock market seeing massive losses, the United States

A new law allows individuals under the age of 60 to withdraw up to $100,000 from their IRAs without facing an early distribution penalty. As Congress begins to implement the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act in the

The IRS can assess a penalty for the failure to timely file a tax return on or before the due date, and a penalty for failing to timely pay the balance shown on a return.  See § IRC 6651(a)(1) and

Both the IRS and the FTB offer the ability to make electronic payments online.  Therefore, the days of manually writing a check and mailing it to the taxing agency via certified mail make little sense, given that secure options exist

Taxpayers should always file their tax return on or before the due date and confirm with their tax return preparer that the return was timely filed.  This means obtaining a copy of the electronic receipt that the accountant received after

IRS Has Begun Sending Letters to Virtual Currency Owners Advising Them to Pay Back Taxes, Files Amended Returns; Part of IRS' Larger Efforts The Internal Revenue Service has begun sending letters to taxpayers with virtual currency transactions that potentially failed

In Dynamex Operations West, Inc. v. Superior Court (Ct.App. 2/7 B249546, Los Angeles County Super Ct. No. BC332016), the California Supreme Court issued a critical decision on the question whether an individual worker should correctly be classified as an employee,

On November 20, 2018, the IRS issued a Memorandum addressing the process for all voluntary disclosures (both domestic and foreign) following the close of the Offshore Voluntary Disclosure Program on September 28, 2018.  In March 2019, the IRS released new

Steven L. Walker recently attended the 34th Annual National Institute on Criminal Tax Fraud and the Seventh Annual National Institute on Tax Controversy, sponsored by the ABA Section of Taxation and ABA Criminal Justice Section.  The conference, which is held

Congress is enacting the biggest tax reform law in thirty years, one that will make fundamental changes in the way you, your family and your business calculate your federal income tax bill, and the amount of federal tax you will

Starting January 1, 2018, appeals of Franchise Tax Board (FTB) decisions will be heard by the Office of Tax Appeals. Created by Assembly Bill 102, known as the Taxpayer Transparency and Fairness Act of 2017, OTA will replace the appellate

On November 3, 2017, the IRS announced the roll out of 11 Large Business and International Compliance Campaigns (LB&I).  (See https://www.irs.gov/businesses/large-business-and-international-launches-compliance-campaigns-0).  LB&I had announced on Jan. 31, 2017, the roll out of its first 13 campaigns to be implemented.  (See

Are you about to embark on a business trip to Latin America or a well-needed family vacation to Italy or Paris?  Do you work for a technology company and frequently travel overseas to Singapore or other Asian countries for work? 

In Bedrosian v. United States, Dep’t of the Treasury, IRS, No. 15-5853, 2017 U.S. Dist. LEXIS 56535 (E.D. Pa. Apr. 13, 2017), Arthur Bedrosian opened a bank account at UBS in Switzerland in the early 1970s, and for years, he

Have you been contacted by a foreign bank and asked to provide documentation to confirm your status as a U.S. person or foreign person pursuant to the Foreign Account Tax Compliance Act (FATCA). Are you being asked to provide a

Have you received a letter from the Internal Revenue Service (IRS) asking you to come in for an interview? Are you the subject of an IRS examination or target of an IRS criminal case? We are likely to see more

The Department of Justice has stepped up is prosecutions on the criminal and civil enforcement side against employers who pyramid (business withholds taxes from employees but intentionally fails to remit them to the IRS over several quarters), pay employees in