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By: Tiffany D. Bell, Esq. Businesses and individuals will receive automatic penalty relief for failure to file certain tax returns and international information returns for the 2019 and 2020 tax years. IRS issued Notice 2022-36 on August 24, 2022, notifying taxpayers that the specified penalties will be waived, or if previously assessed, abated, refunded or credited. IRS announced the penalty
By: Justin J. Andreozzi, Esq. In recent years, many high earning and wealthy New York residents have departed NY State to escape the ever-increasing burden of State and Local taxes. While the prospect of paying no State income tax is appealing, NY State has a strong incentive to review these moves to ensure that are indeed changes in domicile and
By: Kevin M. Murphy, Esq. We have all seen reports and studies lately regarding the “tax gap”, including one from the Treasury Inspector General for Tax Administration (TIGTA) describing millions lost to tax avoidance. These are usually followed by a statement from a member of Congress stating the urgent need to revise tax laws to collect more revenue from wealthy
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 placed on taxpayers was requiring many businesses to offer minimum essential coverage to its employees. While much has been made of the substantive requirements of
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 Compliance for Virtual Currency Transactions”), events, good and bad, continue to arise that create tax planning and management opportunities for investors. Take, for example, Bitcoin’s recent dive from its high of some
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 comes after the Service’s recent win in the U.S. Tax Court in Caylor Land & Dev. v. Commissioner, T.C. Memo 2021-30 (2021). This win marks the fourth major victory in this area,
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 that a foreign corporation is not exempt from U.S. taxation if it is engaged in a U.S. trade or business, even if it has no effectively connected U.S. income or its income
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 27th, 2020, and addressed a number of specific bankruptcy issues which had not been addressed as a part of either the original Coronavirus Aid, Relief, and Economic Security Act (the “CARES
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 virtual currencies should be treated. FinCEN, the agency under the U.S. Treasury Department tasked with administering the Foreign Bank Account Reporting (“FBAR”) requirements, has previously indicated that virtual currencies are
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 withhold and pay those taxes throughout the 2021 calendar year. On August 8, 2020, President Trump issued a Memorandum directing the Treasury Secretary to use his authority under I.R.C. Section 7508A, which