Authors

17
Feb

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 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

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9
Feb

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 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

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26
Jan

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 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

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21
Jan

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 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

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22
Dec

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 Paycheck Protection Program (PPP) loans. IRS caused a stir earlier this year when it issued IRS Notice 2020-32 which told taxpayers that such otherwise-deductible expenses lose their character if they’re paid with forgiven PPP loans.  The

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3
Dec

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 those businesses will be forced to consider a bankruptcy filing. Ironically, legislation enacted by Congress just prior to the COVID-19 pandemic, may have created a much-needed lifeline for many of

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15
Jul

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 of the country began to shutdown, the People First Initiative relieved taxpayers of many impending tax burdens. Filing deadlines were extended, installment payment agreements were suspended, and

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26
Jun

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 hundreds of non-filer audits against high income individuals and those with related flow-through entities. The original announcement of this initiative came in July, 2019, when LB&I added high income non-filers

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5
May

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 initiatives to help individuals and businesses navigate financial problems resulting from the Covid-19 Pandemic. The details related to many of those programs have been highlighted in numerous blogs and

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11
Feb

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 approval for certain penalties proposed by the IRS.  Much of RRA 98 focused on legislative controls to prevent abusive practices by IRS personnel which had come to light in the

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