Recent Microcaptive Letters are an IRS Gift in Disguise... [ read ]
I recently blogged on the IRS' mass mailing of soft-contact letters to microcaptive participants. Although perceived as a nuisance, it is an early Christmas present from the IRS – the gift of time to assess the planning, shore up defenses, and in some instances, to remediate.
Texas Comptroller Delays Implementation of New Policy Regarding the Taxability of Medical Billing Services Until After 2021 Legislative Session... [ read ]
Last week, the Texas Comptroller issued an important memo regarding the taxation of medical billing services. The memo is dated March 19, 2020 and follows up on a prior memo dated November 19, 2019, which had previously announced the reversal of a long-standing Comptroller policy treating medical billing services as nontaxable.
The Texas Comptroller Issues Potential Life-line for Struggling Businesses: But Proceed with Caution!... [ read ]
This week, the Texas Comptroller issued a potential life-line to businesses that are struggling to pay their taxes in light of COVID-19, but taxpayers should proceed with caution.
So You Think the IRS Extended All April 2020 Deadlines? Think Again. **And Again.**... [ read ]
In IRS Notice 2020-18, the IRS automatically extended the April 15, 2020 due date for federal income tax returns and federal income tax payments to July 15, 2020. The IRS made clear, however, that "no extension" is provided for the payment or deposit of any other Federal tax or the filing of any other Federal return. So what stays on the April 2020 to-do list?
IRS Invites En Masse Microcaptive Participants to Amend Returns: Should Taxpayers Accept?... [ read ]
In a move that some might consider tone-deaf, the IRS has done a mass mailing to microcaptive participants, boasting of its wins in Tax Court, and inviting taxpayers to amend prior year returns to remove the Federal tax benefits claimed relative to their captive insurance planning. Do taxpayers accept this invite and if not, how should they respond to this IRS letter?
UPDATED: So You Think the IRS Extended All April 2020 Deadlines? Think Again. **And Again.** And Again.**... [ read ]
In IRS Notice 2020-18, the IRS automatically extended the April 15, 2020 due date for federal income tax returns and federal income tax payments to July 15, 2020. The IRS made clear, however, that "no extension" is provided for the payment or deposit of any other Federal tax or the filing of any other Federal return. So what stays on the April 2020 to-do list?
COVID-19 May Cause Defaults in Compromise and Settlement Agreements with the Texas Comptroller... [ read ]
Along with the many ails COVID-19 brings to the table is the possibility that it will cause a default on payments due under Compromise and Settlement Agreements with the Texas Comptroller.
"Please Sir, I Want Some More" Information About Your Reportable Transactions in 2019, Says the IRS... [ read ]
Each year taxpayers are required to disclose their participation in a reportable transaction by filing a Form 8886 with the IRS. In recent years the IRS has added both Section 831(b) micro captives and syndicated conservation easements to the list of reportable transactions. As taxpayers eye the filing deadline for their 2019 disclosures, the IRS has revised the Form 8886 and instructions to request even more information about a taxpayer's reportable transactions.
The Who, What, When and Where of IRS Form 8938, Statement of Specified Foreign Financial Assets... [ read ]
IRC Section 6038D requires any taxpayer who has an interest in a "specified foreign financial asset" to disclose that asset to the IRS on a Form 8938 attached to the taxpayer's annual tax return. The penalty for failure to file Form 8938 is $10,000. If failure continues for more than 90 days after notification by the IRS, an additional penalty of $10,000 will apply for each 30-day period during which the failure continues. The maximum penalty for a continuing failure to file a Form 8938 is $50,000.
The Who, What, When and Where of FBAR/FINCEN Form 114... [ read ]
What is an FBAR? Every year taxpayers must report certain foreign financial accounts, such as bank accounts, brokerage accounts and mutual funds, to the Treasury Department and keep certain records of those accounts. Taxpayers report the accounts by filing a Report of Foreign Bank and Financial Accounts (FBAR) on FinCEN Form 114.
