Resources Archive
October 9, 2020
The IRS uses the 5-Letter "F" word in relation to Syndicated Conservation Easements...
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I know what you are thinking: I can't count letters. But the truth is far worse. The IRS used the five-letter "F" word: Fraud.
October 8, 2020
Amended Tax Return or Superseding Tax Return?...
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I recently had one of those "aha" moments and thought it was blog-post worthy. A tax return preparer called me after a tax return he tried to electronically file was rejected by the IRS because a return had already been filed for the taxpayer for same tax period. The first thought is: this is a case of stolen identity and a fraudulent return, right? In most cases, yes; but in this case, wrong. Upon further investigation, the preparer found that his office had inadvertently filed an incomplete return for the taxpayer, ten days before. In fact, the return that was filed was completely blank.
October 2, 2020
IRS Stands Firm on Microcaptive Settlement Terms and Warns of Similar Treatment for Variations...
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Lest we forget the IRS' position on microcaptives, yesterday the IRS issued a reminder to taxpayers that they should consult an "independent tax advisor" to size-up their captive insurance planning because "any future settlement terms will only get worse, not better." This warning applies not only to Section 831(b) microcaptives, but also variations that do not involve a Section 831(b) election that the IRS also identified as abusive.
September 29, 2020
IRS Has Requested Comments on Ending Revenue Procedure 94-69 Disclosures As a Defense to Penalties...
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On August 19, 2020 the IRS requested comments on whether it should eliminate disclosures made under Revenue Procedure 94-69, which allows taxpayers to avoid accuracy-related penalties with respect to self-reported adjustments at the beginning of an IRS audit
September 29, 2020
HILL TAX BRIEFING: Taxes in Focus Heading Into First 2020 Debate...
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Josh Ungerman was quoted in the Bloomberg article, "HILL TAX BRIEFING: Taxes in Focus Heading Into First 2020 Debate," by Colin Wilhelm, Kaustuv Basu and Patrick Ambrosio on September 29, 2020. Reproduced with permission. Published September 29, 2020. Copyright 2020 by BGOV LLC (877-498-3587)
September 23, 2020
Accounting Continuing Professional Education Network (ACPEN) 2020 Business Fraud Update Webcast... [ read ]
September 17, 2020
COVID Crisis Prompting the Need for a Private Letter Ruling in a Flash? No Problem....
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Is COVID to blame for you missing a tax election, inadvertently terminating an election, or making the wrong election? Do you need immediate IRS attention… during a global pandemic when most IRS offices are closed? Don't you worry – the IRS is urging taxpayers to take advantage of expedited handling for private letter ruling requests to give you the tax certainty you need, when you need it.
September 16, 2020
To Forgive or Not to Forgive (in 2020): That is the PPP Question...
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For the many businesses that secured a potentially forgivable loan under the Paycheck Protection Program (PPP), one of the more pressing issues is whether to apply for forgiveness now or later and the tax implications of forgiveness in 2021 with respect to 2020 expenses that may become non-deductible upon forgiveness. So what is the right answer?
September 16, 2020
Missed Yesterday's Deadline? Just "COVID-19" It....
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While the IRS has refused any formal program for late penalty relief, informally the IRS is embracing the virtue of forgiveness, with the magic word being "COVID-19."
September 16, 2020
Taxpayers' FBAR Fifth Amendment Gambit Fails...
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Josh Ungerman was quoted in the TaxNotes article, "Taxpayers' FBAR Fifth Amendment Gambit Fails," by Andrew Velarde on September 16, 2020.
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