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IRS Has Requested Comments on Ending Revenue Procedure 94-69 Disclosures As a Defense to Penalties
By on September 29, 2020
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
COVID Crisis Prompting the Need for a Private Letter Ruling in a Flash? No Problem.
By on September 17, 2020
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.
To Forgive or Not to Forgive (in 2020): That is the PPP Question
By on September 16, 2020
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?
Missed Yesterday's Deadline? Just "COVID-19" It.
By on September 16, 2020
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."
IRS Launches Helpful Learning Resource on the New Rules Governing Partnership Audits
By on September 2, 2020
Yesterday the IRS launched a new website for taxpayers and tax practitioners seeking information on the centralized partnership audit regime. As many of you will recall, in 2015 Congress exchanged one set of overly-complicated audit rules applicable to partnerships, known as TEFRA, with a different but comparably complicated set of partnership audit rules known as BBA (after the enacting legislation, the Bipartisan Budget Act). The new audit regime is generally effective for tax years beginning January 2018.