Tax Matters Blog
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Stay in the know with Andreozzi Bluestein LLP
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 ...
Read moreThe 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 ...
Read moreBankruptcy 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 ...
Read moreVirtual 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 ...
Read moreEmployers 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 ...
Read moreFinally 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 ...
Read moreSubchapter 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 ...
Read moreIRS 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 ...
Read moreHigh 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 ...
Read moreDebt, 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 ...
Read moreIRS 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 ...
Read moreUpdate 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 ...
Read moreFederal 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 ...
Read moreState 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 ...
Read moreNew 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 ...
Read moreTax 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 ...
Read moreOptional 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 ...
Read moreRecent 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 ...
Read moreNew 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 ...
Read moreIRS 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 ...
Read moreOur 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 ...
Read moreIRS 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 ...
Read moreWHY 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 ...
Read more“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 ...
Read moreVoluntary 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 ...
Read moreThink 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 ...
Read moreClient 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 ...
Read moreUnderstanding 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 ...
Read moreIntroduction to IRS Appeals and the U.S. Tax Court (Part 3)
By: Michael J. Tedesco, Esq. Introduction to IRS Appeals IRS Appeals is a separate branch of the IRS, whose purpose is to resolve tax controversies between the IRS and taxpayers through an informal, ...
Read moreUnderstanding Audit, Issues and Strategies (Part 2)
By: Heather L. Marello, Esq. Types of Audits Pursuant to the IRS Data Book, during calendar year 2016, the IRS audited almost 1.1 million tax returns, or 0.5% of all returns filed. A representative ...
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