2024-02-19 Insurers Update BOI Guidance

This week we look at:

• Insurers updating their advice on BOI engagements

• SALT cap 2023 increase bill fails on a procedural vote in the House

• Jury finds taxpayer did not willfully fail to file FBAR reports

• IRS takes position third party payors liable for ERC refund repayment in addition to common law employers

• IRS sending out CP271 “soft letters” to those with open ERC refund claims

• S corporation has a failure of 9 trusts receiving shares from decedent

• Taxpayer unsuccessfully argues she only should pay taxes on social security actually received

An audio only version of this week’s broadcast can be streamed or downloaded below:

This week’s slides and citations can be downloaded as a PDF below:

2024-02-19 Current Federal Tax Developments

2024-02-12 Are You Giving Bad Advice on Electronic Filing?

This week we look at

• No movement on tax bills this week - nor is final action at all likely to take place before March

• E-Filing returns - good or bad idea? Two competing articles published this week

• Taxpayer owes tax on IRA forfeited to government as part of criminal conviction

• IRS discusses when CID voluntary disclosure program should be used instead of ERC voluntary disclosure program

• IRS warns about EFIN scam emails

• Taxpayer found to have submitted a late new refund claim rather than a revision to a timely filed informal claim

An audio only version of this week’s program can be streamed or downloaded below.

A PDF copy of the slides and links can be downloaded below:

2024-02-12 Current Federal Tax Developments

2024-02-05 More Movement on Proposed Retroactive Tax Bills

This week we look at:

• Bipartisan extender bill is passed by the House, but faces uncertain future in the Senate

• A limited, single-year SALT cap relief bill will be brought to the House floor as part of the compromise to pass the bipartisan bill

• Tax filing season for 2023 return begins this week

• A cautionary tale about phishing being used to obtain client tax information

An audio only of this week’s broadcast can be streamed or downloaded below:

The slides and links to information are available to download below:

2024-02-05 Current Federal Tax Developments

2024-01-29 Bipartisan Retroactive Tax Bill Clears Ways and Means Committee

This week we look at a proposed tax bill that has advanced out of the House Ways & Means Committee.

An audio only version of this week’s broadcast can be downloaded or streamed via the link below:

A copy of the slides with links to materials can be downloaded below.

2024-01-29 Current Federal Tax Developments

2024-01-16 Form 8308 Relief

This week we look at:

• Talks continue on proposed tax bill

• IRS provides guidance on Pension-Linked Emergency Savings Account anti-abuse provisions

• Relief granted for filing information found in Part IV of Form 8308 for 2023 returns

• IRS updates Notice describing how to obtain certain exemptions from the required electronic filing of certain entity information and tax returns

An audio only version of this week’s broadcast can be downloaded below:

The citations for this week’s program can be downloaded below:

2024-01-16 Current Federal Tax Developments

2024-01-08 IRS Mistake Stands as Taxpayer Benefits

This week we look at:

• New work in progress to try and obtain a bipartisan tax bill

• IRS gives car dealers a brief extension to file time-of-sale reports

• IRS reverses direction on treatment of impact of adding a tax reimbursement clause to an IDGT

• Taxpayer can rely upon date IRS places in Notice of Deficiency as the last day to file a Tax Court petition

An audio only version of this week’s podcast can be downloaded or streamed below.

Articles on this week’s updates can be downloaded below:

2024-01-08 Current Federal Tax Developments

2024-01-02 FinCEN Welcomes 2024 By Opening BOI Filing Site

This week we look at FinCEN's release of the BOI E-Filing site on January 1, 2024.

An audio only version of this week’s broadcast can be streamed below

A copy of this week’s slides and the BOI form can be downloaded via the links below:

2024-01-02 Current Federal Tax Developments

FinCEN Beneficial Ownership Information Form

2023-12-26 IRS Plays Santa With Two Relief Programs

This week we look at:

• IRS announces a three month Employee Retention Credit Voluntary Disclosure Program

• IRS provides relief from failure-to-pay penalties for 2021 and 2020 taxes for certain situations

• Taxpayer uses the wrong FedEx service, therefore his Tax Court petition was not filed on time

An audio-only version of this week’s broadcast can be downloaded or streamed below:

Articles related to this week’s updates can be downloaded below:

2023-12-26 Current Federal Tax Developments

2023-12-18 FinCEN BOI Week

This week we look at:

• FinCEN adds more information to FAQ page, including information on PDF form

• Bill passes House that would give a limited extension of time for some initial BOI reports to be filed

• IRS releases mileage rates for 2024

• Supreme Court agrees to hear estate tax valuation case to resolve split in the Circuits

An audio-only version of this week’s broadcast can be streamed or downloaded below:

Slides and links to articles for this week’s update can be downloaded below.

2023-12-18 Current Federal Tax Developments

2023-12-11 First ERC Challenge in Court

This week we look at:

• IRS sends out a batch of 20,000 ERC rejection letters

• Employer files suit claiming IRS ERC guidance violated the Administrative Procedures Act

• SCOTUS hears oral arguments in the Moore case

• Draft K-2/K-3 instructions are published with no major changes to the domestic filing exception for 2023

An audio-only version of this week’s broadcast can be streamed or downloaded below:

A PDF with the slides and links for this week can be downloaded below:

2023-12-11 Current Federal Tax Developments

2023-12-04 State Law Limited Partners and Self Employment Tax

This week we look at:

• FinCEN finalizes extension of due date for initial BOI reports for entities created in 2024

• Tax Court rules that a state law limited partner is not automatically covered by IRC §1402(a)(13) self-employment tax exemption

• OPR due diligence alert on FBAR

• Annual business MeF shutdown date announced IRS denies request for automatic accounting method change late election relief

• Tax Court finds that if date to file a Tax Court petition falls on a date that the clerk’s office is inaccessible, the taxpayer qualifies for extended filing relief even though electronic option had been available on the due date

An audio only version of this week’s broadcast can be downloaded or streamed below:

A copy of the slides and links to the materials can be downloaded below:

2023-12-04 Current Federal Tax Developments

2023-11-27 FinCEN Becomes Part of ERC Fraud Enforcement

This week we look at:

• IRS delays certain parts of expanded Form 1099-K filings added in ARPA to 2024 tax years

• FinCEN enters the ERC fraud enforcement game, publishing 10 red flags for financial institutions to use to identify suspicious transactions that may need to be reported to FinCEN

An audio only version of this week’s update can be streamed or downloaded below:

Slides and links to materials for this week’s update can be downloaded below:

2023-11-27 Current Federal Tax Developments

2023-11-20 FinCEN FAQ Update for BOI Reporting

This week we look at:

• IRS clarified FAQ on §139A and backpay for wrongfully incarcerated members of the armed services

• FinCEN adds to the FAQ on beneficial ownership information reporting

An audio-only version of this week’s broadcast can be streamed or downloaded below:

This week’s slides and citations can be downloaded below:

2023-11-20 Current Federal Tax Developments

2023-11-13 IRS Completes Inflation Adjusted Number Lists for 2024

This week we look at:

• Inflation adjusted numbers for 2024 issued by the IRS

• Minor revisions made in final BOI FinCEN Identifier rules

• The IRS issues its second ERC-related GLAM, this time taking aim at OSHA related partial shutdown theories

• If a Notice isn’t binding on the courts, does that mean we can just pretend it doesn’t exist when advising our clients?

The slides and links to documents and articles can be downloaded below.

2023-11-13 Current Federal Tax Developments

2023-11-06 Retirement Plan Numbers Released for 2024

This week we look at:

• 2024 inflation adjusted retirement numbers released by the IRS

• MeF 1040 shutdown date announced by the IRS

• Trust found liable for transferee tax in failed Son-of-BOSS shelter to offset stock sale gain

• IRC §41 refund claim grace period extended for yet another year

• Tax Court refuses to expand equitable relief for missing 90-day deadline to file petition

An audio only version of this week’s update can be downloaded or streamed below:

A copy of the slides and links to the documents can be found below:

2023-11-04 Current Federal Tax Developments

2023-10-30 Boyle Decision Applies to Electronic Filing

This week we look at

• Taxpayers can’t rely on paid preparer as reasonable cause for late filing, even when using electronic filing

• IRS could assert negligence penalty (and obtain supervisory approval) after failing to obtain approval for substantial underpayment penalty

• IRS makes “temporary” electronic signature program permanent by moving it into the Internal Revenue Manual

An audio only version of this week’s update can be streamed or downloaded below:

The slides and links to documents for this week’s update can be downloaded at:

2023-10-30 Current Federal Tax Developments

2023-10-23 An Offer The Actor Should Have Refused

This week we look at

• PTIN renewals are now open for 2024

• IRS announces program to allow for withdraw of ERC claims

• Actor’s estate loses in attempt to claim he had validly rolled over a non-traditional investment held in his IRA

This week’s slides and supporting document links:

2023-10-23 Current Federal Tax Developments

2023-10-09 EV Credit Transfer to Dealer Guidance Issued

This week we look at

• Sloppy records cost CPA the vast majority of his business deductions

• IRS issues warning about art deduction tax promotions aimed at high-income taxpayers

• IRS gives details on transfers of electrical vehicle credits to dealers beginning in 2024

An audio only version of this week’s broadcast can be streamed or downloaded below:

The slides and links to the documents discussed can be downloaded via the link below:

2023-10-09 Current Federal Tax Developments

2023-10-02 Limited Delay in Some CTA BOI Initial Report Filing Dates

This week we look at:

• IRS reduces PTIN fees substantially

• Wash sale rules do not apply to losses on disposition of money market funds

• IRS highlights new capabilities added to TaxPro accounts

• Employers can set up leave-based donation programs for 2023 Hawaii wildfire relief

• FinCEN grants 60 additional days for entities created in 2024 to file initial reports

An audio-only version of this week’s broadcast can be streamed or downloaded below:

A PDF of the slides and links to supporting materials can be downloaded below:

2023-10-02 Current Federal Tax Developments

2023-09-25 FinCEN Issues Guide for Small Business CTA BOI Reporting

This week we look at:

• FinCEN provides guide to small businesses for beneficial ownership reporting under the Corporate Transparency Act

• Taxpayer cannot rely on the mailbox rule to prove timely mailing/filing of tax return, as §7502 is the sole way of proving timely postmark and get presumption of delivery

• Impact of receipt of a CP2100/2100A notice on backup withholding

The audio only version of this week’s broadcast can be streamed or downloaded below:

A PDF with the slides and links to articles can be downloaded below:

2023-09-25 Current Federal Tax Developments