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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: 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
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 2020-18) and they also provided some payment relief in response to the COVID-19 national emergency. Although this is an ever-evolving and fluid situation, for the time being the Treasury
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 for individuals and up to $10 million for corporations on their tax payments for up to 90 days. Taxpayers are still encouraged to file their tax returns
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: 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,
By: Heather L. Marello, Esq. The Bank Secrecy Act of 1970, Pub. L. 91-507, 84 Stat 114 (Oct. 26, 1970), addressed the government’s desire to monitor the use of foreign bank accounts for illegal activities by authorizing the Secretary of the Treasury to require U.S. citizens, residents, and others to “keep records, file reports, or keep records and file reports,