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Form 8275 Disclosure Statement: A Tax Practitioner's Best Friend Forever
By on July 17, 2020
There is no denying it. My Best Friend Forever, my BFF, is IRS Form 8275 – which I affectionately call Disclosure Statement. The reason being, Form 8275 keeps me and my clients (mostly) out of trouble. And it can do the same for you and your clients.
IRS Releases 2020 Dirty Dozen List: What Made the Cut?
By on July 16, 2020
Sometimes it better not to be noticed. And that is certainly true when it comes to the IRS' Dirty Dozen list – the IRS' proverbial "naughty" list of abusive transactions, fraudulent schemes, and criminal scams. In the list for 2020 released today, the IRS focuses on scams that target taxpayers. And for the first time since 2014, the IRS leaves off one allegedly-abusive transaction.
The IRS Publishes a Roadmap for Bipartisan Budget Act (BBA) Partnership Audits
By on July 9, 2020
On July 6th, the IRS published a BBA Roadmap for Taxpayers to assist partnerships subject to the centralized partnership audit regime. The centralized partnership audit regime was created in the Bipartisan Budget Act of 2015 and applies to partnership tax years beginning after December 31, 2017. Although the IRS has already started some BBA audits, the release of the roadmap is likely an indication that more partnership audits will be starting soon.
IRS Releases Practice Unit on Reasonable Cause and Good Faith Defenses to Penalties
By on July 7, 2020
On July 2, 2020, the IRS released a practice unit addressing a taxpayer's reasonable cause and good faith defenses to civil penalties. IRS practice units are developed through internal collaboration and serve as both job aids and training materials on tax issues. Practice units provide a general discussion of a concept, process or transaction and are a means for collaborating and sharing knowledge among IRS employees. A list of the IRS practice units can be found here. Although practice units are not official pronouncements of law or directives and cannot be used, cited or relied upon, they provide insight to taxpayers and tax advisors.
Working With the New IRS Independent Office of Appeals
By on July 6, 2020
On July 1, 2019, the Taxpayer First Act was signed into law and among other things, it established the "Internal Revenue Service Independent Office of Appeals". The IRS Office of Appeals has been around for almost 100 years and has generally been independent. However, the Taxpayer First Act codified the Office of Appeals and its long-standing purpose and duties, i.e., " to resolve tax controversies, without litigation, on a basis which is fair and impartial to both the Government and [the taxpayer] in a manner that will enhance voluntary compliance and [public confidence} in the integrity and efficiency of the Service".
