Last week, in a government notice of proposed rulemaking (REG-106227-22), US Treasury and the IRS issued proposed regulations that identify any transaction that is similar to a Malta personal retirement scheme as a “listed transaction.”
The IRS recently issued its seventh warning against questionable ERC activity. The IRS, with its new funding, is expected to ramp up its Employee Retention Credit (ERC) audit enforcement. The IRS ERC audit process is
Parag Patel Esq. will be a featured speaker next week at the annual state convention of the New Jersey Society of Certified Public Accountants (NJCPA) in Atlantic City, NJ. The seminar is entitled “ Hot
Parag Patel Esq. was the featured speaker last month at a New Jersey Society of Certified Public Accountants (NJCPA) Nonprofit Interest Group. The Group is a resource for NJCPAs for accounting and auditing issues affecting
Several clients have recently asked us about the Mark-to-Market (MTM) election for a Passive Foreign Investment Company (PFIC). A MTM election for a Passive Foreign Investment Company (PFIC) is an option that allows a taxpayer
The Florida Bar Tax Section recently made some excellent comments in response to the Internal Revenue Service’s request for comments concerning Forms 3520 and 3520-A. The comments were intended to enhance the quality, utility, and
Join us for a Complimentary CPE Presentation on Reporting Foreign Assets & Activities: Requirements and Challenges Penalty structure Best practices in reporting IRS penalty avoidance programs Latest Supreme Court case impacting FBAR penalties Summary of most
Last week the US Tax Court issued its opinion in Farhy v. Commissioner, ruling that the Internal Revenue Service (IRS) could not assess or collect penalties under Internal Revenue Code (Code) Section 6038(b) for a late-filed Form 5471 against Alon
The US DOJ Tax Division recently conceded penalties assessed against a police officer for failing to file informational returns on for a foreign gift. Krzysztof Wrzesinski, a Polish-American citizen, had failed to file Form 3520,
The US Supreme Court rarely hears tax cases, but this week ruled on a case in favor of taxpayers. The case was originally heard because lower courts issued conflicting opinions. This week, the Supreme Court
The IRS is planning to hire thousands of new agents in the next few years. Some politicians and the media have portrayed the new hires as a harassing threats to taxpayers. In my decades of
On December 22, 2022, New Jersey Governor Murphy signed into law a new rule that eliminates the need to make separate New Jersey S elections. The law primarily conforms New Jersey’s laws regarding the making of
