A CDPH is an administrative hearing held before the IRS Office of Appeals (“Appeals”) offered only once per tax period for a lien and once for a proposed levy action. Prior to taking forced collection action and shortly right after a lien is filed, the IRS allows a...
Year: 2023
How does Greenberg’s Express apply to FDR cases with foreign assets?
It is not uncommon for those who find themselves the subject of an audit to believe that they were unfairly targeted. This is especially true for those who hold foreign assets or business interests. Taxpayers who need to navigate tax compliance with these types of...
Ms. Kundra is moderating the IRS Employment Tax Update and State Employment Tax at the ABA Virtual 2023 Fall Tax Meeting
October 18th, 2023, from 12:30pm EST to 2pm EST. Panels: IRS Employment Tax Update Legislative Updates - State Employment Taxes
Tax Updates In October 2023
IRC §61: Fringe Benefits & Noncommercial Flight Valuation IRS provides Standard Industry Fare Level cents-per-mile rates and terminal charge in effect for 2nd half of 2023 to determine value of non-commercial flights on employer-provided aircraft under Reg. §...
IRS Establishes Special Pass-Through Unit For High-Income Compliance Blending New Workgroup and Current Employees
IRS Issue Number: 2023-38 The IRS’ focus continues on high-income compliance issues, with its plans to hire 3,700 more people and use AI to create a special area focusing on large or complex pass-through entities. While the new Unit will be housed in the IRS Large...
When Dealing with the IRS, What Do You Have The Right To Know?
Here is what you have the right to know: When the IRS has finished an audit. The maximum amount of time you have to challenge the IRS' position. How long the IRS can audit a particular tax year How long the IRS can collect on a tax debt. The IRS generally has 3...
Tax Updates In August 2023
Beneficial Owners Must be Disclosed. In accordance with the Corporate Transparency Act (CTA), on January 1, 2024, many corporations, limited liability companies, and other entities created or registered to do business in the United States must report information about...
Who is a related party for foreign-owned US corps?
Non-US citizens can face tax obligations if they own a US business and are “engaged in a trade or business in the United States.” This means the Internal Revenue Service (IRS) will likely expect tax filings if your business sells products or services in the United...
How do I comply when delinquent on FBAR filing?
The U.S. Tax Code is a complex beast. Navigating the rules for reporting assets and filing the appropriate forms is no easy task. Add additional factors like business interests and foreign assets, and the process can quickly become unmanageable. What happens when you...
August 2023 Tax Updates By Tax Attorney Chaya Kundra
IRC §41 & Research Credits: Certain research activities undertaken by apparel retailer/taxpayer with respect to development of business component may be for qualified purpose under Code Sec. 41(d)(3). Also, research activities with respect to development of...