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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: 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
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
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
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
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
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 exceeds $10,000 and the taxpayer is not in an installment payment arrangement or have an accepted Offer in Compromise by the Tax Department. When the law
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 burgeoning cryptocurrency market. As taxpayers enter this market, it’s important that they understand that virtual currency transactions are taxable events involving actual assets and that the IRS treats
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 Recovery Penalty. As a follow up, we wanted to pass along a recent news release from the IRS that highlights the conclusion of an unprecedented two
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 statute is virtually identical to the criminal statute. The two statutes are highlighted below: Section – IRC 6672 (Civil) Any person required to collect,