The Tax Code and additional Congressional action have given the Internal Revenue Service (IRS) many different tools to come after employers as well as those they consider responsible parties who fail to withhold and remit employment taxes. One such example is the...
Allocation of Income Regs Valid Under Chevron, State Farm Says USTC. See, 3M Company and Subsidiaries, (2/9/2023) 160 T.C. No. 3, where the Tax Court upheld the proposition that various regulations under Code Sec. 482 are valid under the two Supreme Court tests for...
Tax attorney Chaya Kundra will co-chair and speaker at the following upcoming events on employment tax updates. Name of event: Employment Tax Update Date: February 10, 2023 Time: 3pm to 4pm Name of event: Employment Tax Issues & Opportunities Impacting M&A...
Supreme Court Hears Arguments on Alternative Attorney-Client Privilege Test. Oral arguments before US Supreme Court on 1/9/23 involving subpoenas of recorded communications comprised of both of tax and legal advice. In re Grand Jury, concerned unnamed law firm...
IRC 2056: Estate granted 120-day extension to make Sec. 2056(b)(7) QTIP election with respect to marital trust where taxpayer acted reasonably and in good faith and granting relief would not prejudice Gov.'s interests. (PLR 202249006) IRC 6330 (CDPH & no face to...
Extra precautions are necessary when buying property in the United States from a foreign seller. This is because the Foreign Investment in Real Property Tax Act (FIRPTA) places certain tax withholding burdens on the buyer if the seller is considered a “foreign person”...
Uncle Sam, the posterchild for the U.S. government and its agencies, brings visions of a strong and demanding force. The Internal Revenue Service (IRS) projects much the same image. This federal agency expects all taxpayers — individuals and businesses alike — to meet...
Reasonable Cause, First Time Abatement, Reliance on a Professional, Exercising Ordinary Care and Prudence A live 110-minute CPE webinar with interactive Q&A Thursday, December 1, 2022 (in 2 days) 1:00pm-2:50pm EST, 10:00am-11:50am PST (Alert: Event date has...
Employment Taxes & Protecting the Business Owner from Personal Liability. We will discuss best practices, speak about increased IRS scrutiny on both the civil and criminal sides, how to avoid paying your company’s taxes personally and what to do when you are over...
President Joseph Biden recently signed the Inflation Reduction Act into law, which, along with many other changes, led to an influx of funding for the Internal Revenue Service (IRS). Treasury Secretary Janet Yellen states that the agency is set to get almost $80...
