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Stay in the know with Andreozzi Bluestein LLP

ACA Penalties Lurking for Unsuspecting Employers

By: Derek B. Wheeler, Esq. It has now been more than a decade since the Patient Protection and Affordable Care Act (ACA) was signed into law by President Obama. Among the many requirements the law ...

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Can We Discern Tax Opportunities From the Haze of the Crypto Horizon?

By: Randall P. Andreozzi, Esq. While we anxiously await Treasury Department guidance on cryptocurrency (See, TIGTA Report of September 24, 2020, “The Internal Revenue Service Can Improve Taxpayer ...

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IRS Flaunts Recent Tax Court Victory in Microcaptive Arena

By: Heather L. Marello, Esq. In a recent press release, IRS is again urging participants in abusive microcaptive insurance arrangements to cease participation in such transactions.  This message ...

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The Tax Court Reminds Foreign Corporations of the Disastrous Consequences of Failing to File Forms 1120-F U.S. Income Tax Returns

By: Heather L. Marello, Esq. I.R.C. § 6012(a)(2) imposes an income tax return filing requirement on “every corporation subject to taxation under subtitle A.”  The Treasury Regulations clarify ...

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Bankruptcy Related Changes Under the CARES Act and the Consolidated Appropriations Act of 2021

By: Daniel F. Brown, Esq. The Consolidated Appropriations Act of 2021 The Consolidated Appropriations Act of 2021 (the “Appropriations Act”) was passed by Congress and became law on December ...

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Virtual Currency Coming to an FBAR Near You

By:  Michael J. Tedesco With the rapid rise of virtual currency, the IRS and Financial Crimes Enforcement Network (FinCEN) were required to make quick decisions on interpretations of how these ...

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Employers Have Additional Time to Withhold Deferred Social Security Taxes from 2020

By:  Michael J. Tedesco The IRS released Notice 2021-11 on January 19, 2021 addressing how employers who elected to defer certain employees’ Social Security taxes (“Applicable Taxes”) can ...

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Finally Some Good News! — Congress Locks In Full PPP Deductibility

By:  Randall P. Andreozzi Congress last night passed COVID-relief legislation that included a much-anticipated provision that allows businesses to deduct qualifying expenses paid with forgiven ...

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Subchapter V Bankruptcy – A potential lifeline for struggling small businesses

By:  Gary P. Bluestein The financial consequences of COVID-19 have been particularly difficult for a large number of American small businesses and with lockdowns accelerating in many states, many of ...

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IRS People First Initiative Ends Today – What happens now?

By:  Derek Wheeler Today, July 15th, the IRS’ People First Initiative will come to an end. Implemented at the end of March as COVID-19 began spreading throughout the United States and large parts ...

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High Income Non-Filers Beware – Audits Are Coming

By:  Heather L. Marello and Kevin M. Murphy During a recent web conference, IRS Large Business and International Division Commissioner Douglas O’Donnell warned that IRS is gearing up to initiate ...

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Debt, Bankruptcy and COVID-19

By: Ruth R. Wiseman, Esq. and Melissa A. Brennan On March 27, 2020, the President signed the Coronavirus Aid, Relief, and Economic Security Act (“CARES”) Act. The act has created numerous ...

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IRS Warns Taxpayers About COVID-19 Scams Related to Economic Impact Payments

The IRS has issued a warning to taxpayers to be cautious about phishing scams pertaining to IRS payments during the COVID-19 pandemic.  These scams can lead to serious tax-related fraud and identity ...

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Update on Recent IRS Actions During COVID-19

There have been a significant number of recent IRS updates that impact taxpayers from both a controversy and compliance perspective. While our focus is to always provide the absolute best tax ...

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Federal Income Tax Return Filing and Payment Relief

Last week, the Treasury Department and the Internal Revenue Service (IRS) announced that the filing deadline for certain returns has been extended from April 15, 2020 to July 15, 2020 (Notice ...

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State and Federal Tax filing deadlines extended to July 15th

Treasury Secretary announced today that the IRS’ tax filing deadline has been extended to July 15th.  This will be welcome news to not only taxpayers but the tax practitioners who were under the ...

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New York State Announces Penalty and Interest Waiver for Sales Tax Filings

As the COVID-19 spreads, taxpayers of all walks of life are affected by the vast actions taken to contain its spread and protect public health. In the face of this public health crisis, we want to ...

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Tax Court Trial Sessions Cancelled

On March 13, 2020 the United States Tax Court determined that, due to the current health crisis, the Tax Court buildings will be closed effective immediately.  Previously scheduled Tax Court trial ...

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Optional 90 Day Extension on IRS Payments

The Trump Administration announced its new economic stimulus plan today which includes an option for taxpayers to delay their tax payments for 90 days.  The plan allows deferrals of up to $1 million ...

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Recent Tax Court rulings may allow refunds of previously assessed penalties

By: Derek B. Wheeler, Esq. and Heather L. Marello, Esq. As part of the Restructuring and Reform Act of 1998 (“RRA 98”), Congress enacted IRC §6751(b)(1), which requires written supervisory ...

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New York Adds an Economic Hardship Exception to License Suspension Statute

By: Heather Marello, Esq. In 2013, New York added Section 171-v to the tax law, which provides that the State may suspend a taxpayer’s driver’s license if his or her tax, penalty and interest ...

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IRS Captive Insurance Global Settlement Offer- Know your options.

By: Randall P. Andreozzi, Esq. In 2016 the IRS issued Notice 2016-66, which identifies certain micro captive insurance transactions as potentially abusive.  The Notice generally describes the ...

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Our View on Cryptocurrency Taxes & the IRS

By: Randall P. Andreozzi, Esq. Cryptocurrency investors be warned.  The IRS is coming for you.  Over the course of several years, the IRS has methodically ramped up its efforts to tackle the ...

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IRS Completes Unprecedented Campaign Targeting Employment Tax Crimes

By: Kevin Murphy, Esq. In our most recent blog post, we discussed the importance of timely payment of payroll taxes and how serious the IRS is taking the issue of criminalizing the Trust Fund ...

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WHY YOU SHOULD ALWAYS PAY YOUR PAYROLL TAXES: A PRIMER ON TRUST FUND RECOVERY PENALTIES (PART 2)-CRIMINAL EXPOSURE

By: Kevin Murphy, Esq. In Part 1, of this blog, we explained and discussed the civil aspects of IRC 6672- the Trust Fund Recovery Penalty (TFRP). At the end of Part 1, we mentioned that the civil ...

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“But It’s Not My Fault” How to Obtain Innocent Spouse Relief

By: Heather L. Marello Married taxpayers often file their annual income tax returns electing “married filing joint” status.  While often beneficial from a tax perspective, spouses rarely ...

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Voluntary Disclosure options for taxpayers after the closing of the OVDP

By: Tiffany D. Bell When the IRS closed the 2014 OVDP last fall, which had provided an avenue for taxpayers to come into compliance with any past offshore tax and information reporting, it left many ...

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Think the IRS is quiet during the Shutdown? Think Again! Another Form 3520 Trap for the Unwary

By: Randall P. Andreozzi Things are emerging from the abyss that is the longest government shutdown in United States history.   Yes, there exist some things so resilient, so pervasive, so constant ...

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Client Privilege – When you have it & when you don’t may surprise you.

By: Gary P. Bluestein Many accountants incorrectly assume that their communications with their tax clients are always privileged and confidential. Unfortunately, sometimes tax cases can cross over ...

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Understanding the IRS Collection Process (Part 4)

By: Margaret Fichtner This is the last entry in our 4-part series of understanding the lifecycle of a tax controversy. In Parts 1, 2 & 3 we discussed an overview of a controversy, understanding ...

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