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TIGTA Report Weighs in on Penalty Abatements
By on August 28, 2015
On July 30, 2015, the Treasury Inspector General for Tax Administration ("TIGTA") released a report evaluating whether penalties assessed by the IRS against taxpayers are being abated in accordance with IRS Appeals criteria. The report underscores the need for skilled advocacy when it comes to penalty abatement requests and the importance of ensuring that taxpayers' requests for penalty abatements both comply with the governing standards of penalty relief and contain sufficient information to justify the relief requested.
ACA Section 4980D Penalties Apply to Large and Small Employers
By on August 19, 2015
Internal Revenue Code section 4980D imposes a $100.00 per day per employee excise tax on any employer that fails to meet certain group health plan requirements. In testimony before the Senate Finance Committee, a policy analyst with the National Federation of Independent Business testified that 18 percent of small businesses are engaged in practices that may subject the employers to the $100.00 per day per employee penalty.
By on August 18, 2015
In U.S. v. Sperrazza, the U.S. Eleventh Circuit recently affirmed the conviction of a Georgia physician who was convicted of three counts of tax evasion, in violation of 26 U.S.C. § 7201, and two counts of structuring currency transactions, in violation of 31 U.S.C. § 5324(a)(3). U.S. v. Sperrazza, No. 14-11972 (11th Cir. Aug. 17, 2015).
The IRS Has Issued You a Notice of Tax Lien, Now What?
By on August 10, 2015
After a taxpayer fails to remit payment on an outstanding tax liability and the IRS issues a demand for payment, the Internal Revenue Code imposes a statutory lien in favor of the government on all property and property rights of the taxpayer. I.R.C. § 6321. The lien dates back to the date of assessment and continues until the liability is satisfied or becomes unenforceable. I.R.C. § 6322.
Major Changes for FBAR and Tax Return Due Dates
By on August 3, 3015
On July 31, 2015, President Obama signed into law H.R. 3236, the "Surface Transportation and Veterans Health Care Choice Improvement Act of 2015." In addition to providing a 3-month, stop-gap reauthorization of the Highway Trust Fund and transferring over $8 billion to the Fund, the Act alters a number of tax-return due dates—for instance, moving the due date for partnership tax returns a month ahead of the due date for corporate tax returns—and changes the due date for filing an FBAR (FinCEN Form 114) to match the filing deadline for individual tax returns.
