Join me for an upcoming Strafford live webinar, "Forms 5471 and 5472: Meeting the Substantially Complete Standards" on Tuesday, July 18, 1:00pm-2:50pm EDT. Click this link for more information: https://www.sp-04.com/r.php?products/tpjtnhhpra. Description Forms 5471...
Rockville Tax Law Blog
Green Book Proposal Could Pave Way For More IRS Penalties
Law360 (March 24, 2023, 8:25 PM EDT) -- The Internal Revenue Service would likely impose more civil penalties on taxpayers than it does now if the Biden administration's recently revived proposal to change requirements for supervisory approval of penalties at the...
TFRP: When the IRS uses it and how it works
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...
Feb 2023 Tax Updates By Tax Attorney Chaya Kundra
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...
Attorney Chaya Kundra Speaking at Two Upcoming Employment Tax Events
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...
Jan 2023 Tax Updates By Tax Attorney Chaya Kundra
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...
Dec 2022 Tax Updates By Tax Attorney Chaya Kundra
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...
Foreign Investment in Real Property Tax Act (FIRPTA) compliance
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”...
How much of my overseas income should I report?
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...
Tax Attorney Chaya Kundra Speaks at Webinar – Foreign Late Filing Notices: Effective Responses for Penalty Abatement
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...