Current Federal Tax Developments

This week we look at:

• New work in progress to try and obtain a bipartisan tax bill

• IRS gives car dealers a brief extension to file time-of-sale reports

• IRS reverses direction on treatment of impact of adding a tax reimbursement clause to an IDGT

• Taxpayer can rely upon date IRS places in Notice of Deficiency as the last day to file a Tax Court petition

An audio only version of this week’s podcast can be downloaded or streamed below.

Articles on this week’s updates can be downloaded below:

2024-01-08 Current Federal Tax Developments

This week we look at FinCEN's release of the BOI E-Filing site on January 1, 2024.

An audio only version of this week’s broadcast can be streamed below

A copy of this week’s slides and the BOI form can be downloaded via the links below:

2024-01-02 Current Federal Tax Developments

FinCEN Beneficial Ownership Information Form

This week we look at:

• IRS announces a three month Employee Retention Credit Voluntary Disclosure Program

• IRS provides relief from failure-to-pay penalties for 2021 and 2020 taxes for certain situations

• Taxpayer uses the wrong FedEx service, therefore his Tax Court petition was not filed on time

An audio-only version of this week’s broadcast can be downloaded or streamed below:

Articles related to this week’s updates can be downloaded below:

2023-12-26 Current Federal Tax Developments

This week we look at:

• FinCEN adds more information to FAQ page, including information on PDF form

• Bill passes House that would give a limited extension of time for some initial BOI reports to be filed

• IRS releases mileage rates for 2024

• Supreme Court agrees to hear estate tax valuation case to resolve split in the Circuits

An audio-only version of this week’s broadcast can be streamed or downloaded below:

Slides and links to articles for this week’s update can be downloaded below.

2023-12-18 Current Federal Tax Developments

This week we look at:

• IRS sends out a batch of 20,000 ERC rejection letters

• Employer files suit claiming IRS ERC guidance violated the Administrative Procedures Act

• SCOTUS hears oral arguments in the Moore case

• Draft K-2/K-3 instructions are published with no major changes to the domestic filing exception for 2023

An audio-only version of this week’s broadcast can be streamed or downloaded below:

A PDF with the slides and links for this week can be downloaded below:

2023-12-11 Current Federal Tax Developments

This week we look at:

• FinCEN finalizes extension of due date for initial BOI reports for entities created in 2024

• Tax Court rules that a state law limited partner is not automatically covered by IRC §1402(a)(13) self-employment tax exemption

• OPR due diligence alert on FBAR

• Annual business MeF shutdown date announced IRS denies request for automatic accounting method change late election relief

• Tax Court finds that if date to file a Tax Court petition falls on a date that the clerk’s office is inaccessible, the taxpayer qualifies for extended filing relief even though electronic option had been available on the due date

An audio only version of this week’s broadcast can be downloaded or streamed below:

A copy of the slides and links to the materials can be downloaded below:

2023-12-04 Current Federal Tax Developments

This week we look at:

• IRS delays certain parts of expanded Form 1099-K filings added in ARPA to 2024 tax years

• FinCEN enters the ERC fraud enforcement game, publishing 10 red flags for financial institutions to use to identify suspicious transactions that may need to be reported to FinCEN

An audio only version of this week’s update can be streamed or downloaded below:

Slides and links to materials for this week’s update can be downloaded below:

2023-11-27 Current Federal Tax Developments

This week we look at:

• IRS clarified FAQ on §139A and backpay for wrongfully incarcerated members of the armed services

• FinCEN adds to the FAQ on beneficial ownership information reporting

An audio-only version of this week’s broadcast can be streamed or downloaded below:

This week’s slides and citations can be downloaded below:

2023-11-20 Current Federal Tax Developments

This week we look at:

• 2024 inflation adjusted retirement numbers released by the IRS

• MeF 1040 shutdown date announced by the IRS

• Trust found liable for transferee tax in failed Son-of-BOSS shelter to offset stock sale gain

• IRC §41 refund claim grace period extended for yet another year

• Tax Court refuses to expand equitable relief for missing 90-day deadline to file petition

An audio only version of this week’s update can be downloaded or streamed below:

A copy of the slides and links to the documents can be found below:

2023-11-04 Current Federal Tax Developments

This week we look at

• Taxpayers can’t rely on paid preparer as reasonable cause for late filing, even when using electronic filing

• IRS could assert negligence penalty (and obtain supervisory approval) after failing to obtain approval for substantial underpayment penalty

• IRS makes “temporary” electronic signature program permanent by moving it into the Internal Revenue Manual

An audio only version of this week’s update can be streamed or downloaded below:

The slides and links to documents for this week’s update can be downloaded at:

2023-10-30 Current Federal Tax Developments