On April 24, 2020, the Internal Revenue Service (IRS) issued an internal memo advising its employees that it would be recalling those employees involved in “mission critical” operations. This internal memo represents the most significant update to the IRS’s “People First Initiative,” a program intended to respond to the challenges of COVID-19 by providing a [...]
The recently imposed social distancing measures that are critical and essential to our nation’s battle with the coronavirus have had a dramatic impact on everyone’s everyday life. No one is exempt or excused from that impact. This includes our nation’s taxing authorities. The Internal Revenue Service (IRS) has created and is updating a website to [...]
The Internal Revenue Service (IRS) announced, in a recent Information Release and Fact Sheet, that it is going to make more site visits to taxpayers who have delinquent-filed tax returns. Fact Sheet 2020-02 notes that this increased use of compliance strategies is being fueled by the IRS’s increased use of data analytics, research, and other [...]
On June 21, 2018, The United States Supreme Court ruled 5-4 in South Dakota v. Wayfair that states can mandate that businesses without a physical presence in a state but with more than 200 transactions in or $100,000 in in-state sales must collect and remit sales taxes on transactions in the state. In this article, [...]
For many taxpayers with multiple active business interests, the material participation test can be a significant tax trap. If the elements of that test are not met, the impact could be that the taxpayer is limited in how the income/loss from that business is recognized on their personal tax return. A recent decision in the [...]
The Internal Revenue Service (IRS) Taxpayer Advocate Service (TAS) recently released the above “subway map” to illustrate, at a very high level, the stages of a taxpayer’s journey through the tax system. The map provides a high level overview of the processes for tax return preparation, tax return processing, notices from the IRS, audits, appeals, [...]
The IRS recently announced that taxpayers who owe tax and did not file their 2018 returns before Friday, June 14, 2019 will be subject to increased late filing penalties. penalty kicks in. The failure-to-file penalty is assessed if there is unpaid tax and the taxpayer fails to file a tax return or request an extension [...]
Yes. If you owe money to the Internal Revenue Service (IRS), the IRS has many tools it may use to collect that money, including foreclosure action against your home. This is usually a tool of last resort for the IRS. The IRS will generally take many other steps to try to collect the outstanding federal [...]
The marijuana industry remains in a difficult position when it comes to the federal tax implications for those involved in that industry. There is more detail here regarding the tax trap facing the marijuana industry. The United States Tax Court (Court) issued a decision in Patients Mutual Assistance Collective Corp., et al. v. Comm’r of [...]
This is the sixth article in the Offshore Voluntary Disclosure Program (OVDP) Frequently Asked Questions series. This series is intended to provide taxpayers and practitioners with answers to the most commonly asked questions relating to the Internal Revenue Service’s (IRS’s) 2012 OVDP. Other posts in this series, offering a basic description of the OVDP and [...]