The U.S. Court of Appeals for the Ninth Circuit today—in a case of first impression for the circuit—held that the IRS is limited to imposing one penalty for the untimely filing of a single accurate
Parag Patel will be a speaker on Estate Planning at the Practicing Law Institute’s (PLI) New Jersey Basic CLE Marathon 2021. Mr. Patel’s presentation will be a general introduction for attorneys practicing in estate planning matters
Parag Patel will be a speaker on Estate Administration at the Practicing Law Institute’s (PLI) New Jersey Basic CLE Marathon 2021. Mr. Patel’s presentation will be a general introduction for attorneys practicing in Estate Administration and
The IRS has announced new initiatives to help taxpayers experiencing Covid-related difficulties (which probably applies to most people) who have unpaid federal tax liabilities. Specifically, the IRS has announced the below relief: · The IRS
When elected, most Presidents have successfully enacted many significant tax proposals in the first two years in office. President Biden is doing things a little differently. Because of the coronavirus pandemic, Biden has divided his
A recent case highlights the rare confluence of tax law and immigration law. This week a federal grand jury indicted Lucia Andrea Gatta, with tax evasion and failing to file Reports of Foreign Bank and
Late last year, the IRS revised the Delinquent International Information Return Submission Procedures (“DIIRSP”, which some people phonetically pronounce as “dersp”) to eliminate language limiting the DIIRSP to situations where the taxpayer has not failed
IRS National Taxpayer Advocate yesterday released her 2020 annual report to Congress yesterday. Federal law requires the Annual Report to Congress to identify the “most serious problems” encountered by taxpayers and to make administrative and
Joe Biden is the President-elect, and the House and Senate are Democratic. There could be massive tax increases on the wealthy, including estate taxes. Clients that did not complete planning in 2020 should be advised
The results of the Georgia Senate election are in and Democrats have secured a Senate majority. As a result, we expect tax changes. President-elect Joe Biden’s tax plans were laid out during his campaign last
During the pandemic many clients’ businesses have adversely impacted by lockdowns and many negotiations between borrowers and lenders have occurred or will occur in 2021. There will be many loan modifications, bankruptcies, and foreclosures. In
COVID-related legislation drove a lot of tax changes for 2020 and President-elect Joe Biden has proposed many tax changes for 2021. With tax laws already very complicated, we have some resolutions to get ahead in
