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Despite NOL Carrybacks, IRS Continues to Deny Refunds of Section 965 Transition Tax Overpayments

By on Apr 29, 2020
Posted In Tax Refunds, Uncategorized

In a series of frequently asked questions (FAQs) addressing the interaction of recently enacted net operating loss (NOL) carryback provisions and section 965, the IRS stated that taxpayers may not receive a refund of any section 965 tax payment unless and until the payment exceeds the “entire income tax liability for section 965.” The IRS...

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IRS Postpones Virtually All Deadlines Until July 15, 2020, in Response to COVID-19

By , , and on Apr 10, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized

In Notice 2020-23, the Internal Revenue Service further expanded relief for taxpayers in response to the Coronavirus (COVID-19) pandemic. Individuals, corporations, trusts, estates and other taxpayers that ordinarily would have had a filing, payment or other deadline between April 1, 2020, and July 15, 2020, now qualify for an extension. Access the full article.

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IRS to Temporarily Adjust Operations and Key Compliance Functions

By and on Mar 26, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized

On March 25, 2020, the Internal Revenue Service (IRS) announced a new People First Initiative designed to provide relief to taxpayers on a variety of issues ranging from easing payment guidelines to postponing compliance actions in light of the challenges caused by the Coronavirus (COVID-19) pandemic. The initiative’s projected start date is April 1, 2020, and it...

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IRS Provides Some Relief from Tax Payment (But Not Filing) Deadlines Due to COVID-19

By , , and on Mar 19, 2020
Posted In IRS Guidance, Uncategorized

On March 13, 2020, President Trump issued an emergency declaration that directed Secretary Mnuchin to provide appropriate relief from tax payment deadlines to Americans who have been adversely affected by the COVID-19 pandemic. In response to this direction, the IRS issued Notice 2020-17. The Notice declares that all taxpayers have been affected by the emergency...

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The Tax Impact of Recent Federal Actions Relating to COVID-19

By and on Mar 18, 2020
Posted In IRS Guidance, Uncategorized

On March 13, 2020, President Trump signed a Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak under the Robert T. Stafford Disaster Relief and Emergency Assistance Act (the “Stafford Act”). By invoking the Stafford Act, the President provides the Internal Revenue Service (IRS) and US Department of the Treasury (the...

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When the IRS Says It’ll ‘Meet You in Paris’: Recent Trends & Developments in Outbound US Exchange-of-Information Techniques

By on Oct 3, 2019
Posted In IRS Guidance, Uncategorized

The Internal Revenue Service is looking for your international tax data—that is, if the IRS doesn’t already have it. With the rollout of the Foreign Account Tax Compliance Act (FATCA) and other automatic exchange-of-information (EOI) procedures, the IRS is now receiving—and making use of—a large amount of international tax information about US taxpayers. In an...

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Courtney Dunbar Jones and Emin Toro Confirmed to Tax Court

By on Aug 7, 2019
Posted In Court Procedure Matters, Trial Courts, Uncategorized

On August 5, 2019, the Senate confirmed Courtney Dunbar Jones and Emin Toro as nominees to the US Tax Court in a voice vote before leaving for August recess. Jones and Toro will now each serve a 15-year term. President Trump had initially nominated each candidate in 2018, but the Senate was not able to...

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Watch Your Mailbox: IRS Letters Warning of Cryptocurrency Non-Compliance on Their Way

By on Jul 30, 2019
Posted In IRS Guidance, Uncategorized

On July 26, 2019, the Internal Revenue Service (IRS) issued a press release informing the public that it is sending more than 10,000 letters to taxpayers with potentially unreported (or misreported) virtual currency transactions. The letters will inform them of the possible reporting requirements that may apply to these transactions and advise them of the...

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Law360: Myers May Make It Easier to Find Equitable Relief in Tax Court

By on Jul 18, 2019
Posted In Appellate Courts, Court Procedure Matters, Trial Courts, Uncategorized

Laura L. Gavioli, PC, recently wrote an article for Law360 on a US Court of Appeals for the District of Columbia Circuit’s decision that may provide an equitable avenue for hearing of late-filed petitions in US Tax Court. The Law360 article, “Myers May Make It Easier to Find Equitable Relief in Tax Court,” can be...

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Is an Increase in LB&I Assertion of Penalties on the Horizon?

By on Jun 5, 2019
Posted In IRS Appeals, IRS Audits, IRS Guidance, Uncategorized

On May 31, 2019, the Treasury Inspector General for Tax Administration (TIGTA) released a report indicating that changes may be in the works regarding assertion of accuracy-related penalties in examinations handled by the IRS Large Business & International (LB&I) Division. The TIGTA report reviewed the results of closed LB&I examinations for the fiscal years 2015...

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