Page 3 – Tax, Estate Planning & Probate Law Center

How to Respond or Contest an IRS Criminal Investigation Division (CID) Summons

19 Jun 24

To contest an IRS Criminal Investigation Division (CID) summons, you generally have a few options: While the most formal way to contest an IRS CID summons is through the court system, there might be a few non-court options to explore,

IRS Criminal Investigation Division Summonses: A Key Tool in Tax Crime Investigations

14 Jun 24

The IRS Criminal Investigation Division (CID) frequently uses summonses to gather evidence in tax crime investigations. These summonses, authorized by law, grant special agents broad authority to examine tax returns, assess liabilities, and investigate any offenses related to tax administration

Form 3520: A Comprehensive Guide to Navigating the Complexities of Foreign Gift Reporting Under the Latest 2024 Proposed Regulations

04 Jun 24

Receiving a gift from a foreign person or entity can be a joyous occasion, but it also carries significant tax implications that necessitate meticulous attention. In the United States, Form 3520 plays a crucial role in ensuring the proper reporting

Detailed Technical Comments and Recommendations to the IRS on Proposed Regulations for Form 3520 and Code Section 6039F (REG-108066-22)

02 Jun 24

The Internal Revenue Service’s (IRS) proposed regulations regarding Form 3520 and Code Section 6039F, as outlined in REG-108066-22, significantly change the reporting requirements for receiving foreign gifts. While the intent behind these regulations is laudable, several aspects warrant closer examination

IRS Issues New Proposed Regs on Information Reporting on Foreign Gifts

09 May 24

The reporting of foreign gifts and inheritances is a very complex part of international tax law. Many of our clients have been hit with large penalties for late filing Forms 3520 to report foreign gifts. Although many of these laws

Form 5471 Penalties Upheld in Latest Court Ruling

08 May 24

The D.C. Circuit handed the IRS a big win last week, holding that the IRS could assess international information return penalties for the failure to file Forms 5471, “Information Return of U.S. Persons With Respect to Certain Foreign Corporations.” The

NJCPA Seminar “The Corporate Transparency Act: What You Need To Know”

22 Apr 24

Parag Patel Esq. is a speaker this week at a New Jersey Society of Certified Public Accountants (NJCPA) Seminar entitled “The Corporate Transparency Act: What You Need To Know”. You may email our office to receive the seminar materials. Seminar

IRS Guidance Targets Cash Reporting in the Cannabis Industry

19 Apr 24

The IRS closely monitors cash transactions to ensure businesses across all industries comply with tax laws. Cannabis businesses, often reliant on cash, face particular scrutiny. A recent IRS memo provides important insights into how the IRS expects cannabis businesses to

IRS International Fines Not Excessive: Form 3520 Penalties Upheld, Form 5471 Penalties Again Unassessable

16 Apr 24

International tax reporting requirements are complex, and the penalties for non-compliance can be severe. In Mukhi v. Commissioner of Internal Revenue, the U.S. Tax Court considered a case involving a taxpayer who faced both criminal charges and significant civil penalties

IRS starting to audit employee retention credit (ERC)

05 Apr 24

Some businesses that claimed the employee retention credit (ERC) have begun receiving IRS letters telling them their claims are on hold because they are under audit and must provide additional information to the agency. Several law firms and media outlets

Questionable ERC could mean trouble for CPAs

29 Mar 24

The Internal Revenue Service announced in March that its compliance efforts related to the Employee Retention Credit had exceeded $1 billion. The agency specified that “more than 12,000 entities filed over 22,000 claims that were improper and resulted in $572

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