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News and Events
Reduction of Tax Attributes under I.R.C. § 108(b)
A taxpayer does not always get to eat cake and keep it too. When discharge of indebtedness (other than real property business debt) is...
Mar 4, 2022
Taxation of the Bankruptcy Estate
The taxation of the bankruptcy state is not always obvious, and below are the key highlights for debtors to keep in mind. The IRS is...
Mar 4, 2022
Handling Audits of Delinquent International Information Returns
This article examines strategies for handling an IRS investigation of international returns, and recommends ways to improve audits,...
Jun 26, 2020
IRS Provides Temporary Relief for Taxpayers in Audits and Collections – Certain Activities Continue
On March 25, 2020, the Internal Revenue Service issued a news release announcing the People First Initiative. See IR-2020-59...
Jun 18, 2020
District Court Lowers Penalties for Form 3520 Nonfiling to Zero
A recent taxpayer-friendly court decision from New York is worth reviewing for practitioners who handle late-filed Forms 3520, Annual...
May 7, 2020
Do You Own a Foreign Corporation? IRS Presses Form 5471 Penalties
The San Francisco Bay Area is a focal point for international business. It is common for individuals to start a business, and later...
Apr 8, 2020
Are You an Owner or Beneficiary of a Foreign Trust or Receive a Foreign Gift or Bequest?
The Government is pressing taxpayers with large civil penalties for late-filed Forms 3520. The IRS may assert the penalty in the context...
Apr 2, 2020
Key Moves in Difficult Times -Options for Taxpayers Facing Economic Uncertainty
We are in tough economic times. A record number of Americans have filed for unemployment benefits, and business owners are forecasting a...
Mar 29, 2020
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