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Tax Provisions of the CARES Act

On March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), which includes tax provisions intended to provide an economic stimulus to both businesses and individuals. The stated policy of the new legislation is to increase cash flow and liquidity and to reduce the cost of capital.

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Michael Sardar Led a Webinar Entitled "Working with Schedule C Taxpayers with Incomplete Records," for the CPA Academy, on March 26, 2020

In the event of a loss of client records or due to poor record keeping, a tax preparer may need to help his client reconstruct the records and/or make estimates. 

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IRS Issues FAQs & Updated Guidance on Extension of April 15 Tax Deadlines Due to Novel Coronavirus (COVID-19)

On March 20, 2020, the IRS issued Notice 2020-18, which provides updated guidance on the extension of the April 15, 2020 tax return filing and payment deadlines due to the Coronavirus pandemic. On March 24, 2020, the IRS issued FAQs to answer various questions regarding Notice 2020-18. 

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Current Overview of the IRS’s Whistleblower Program

By Juliet L. Fink
The CPA Journal
March 2020 Edition

Section 7623 of the Internal Revenue Code (IRC) allows for the payment of financial awards to those who blow the whistle on individuals or corporations that have deliberately underreported or underpaid their taxes. Such awards are based on the amount ultimately paid in such cases. This article explains the details of the whistleblower award program, including recent legislation and litigation that affect whistleblowers and their claims.

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New IRS Guidance Regarding Certain Tax-Favored Foreign Trusts

In new IRS guidance, certain foreign trusts receive a significant break from information reporting and the potential refund of penalties.

The IRS will now exempt eligible U.S. persons from reporting transactions with, or ownership of, certain tax-favored foreign trusts that are operated exclusively (or nearly exclusively) to provide pension, retirement, medical, disability, or education benefits. Such foreign trusts are likely to include programs such as Canadian registered educational savings plans and registered disability savings plans (RESPs and RDSPs); and UK self-invested personal pensions (SIPPs).

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Megan L. Brackney Quoted in TaxNotes Article Entitled, “Practitioners Fault Accelerated Assessable Penalty Collection”

In a TaxNotes article entitled, “Practitioners Fault Accelerated Assessable Penalty Collection,” Megan Brackney is quoted on how “the IRS’s collections practice for assessable penalties related to foreign information returns is increasingly placing taxpayers in a bind, and practitioners are eager to provide suggestions on how the process can be improved.”

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Streamlined Disclosure in U.S. v. Brian Nelson Booker: A Former CPA Sets a Dubious Precedent

By Sharon L. McCarthy
The CPA Journal
March 2020 Edition

Brian Nelson Booker has the dubious distinction of being the first person criminally charged by the Department of Justice (DOJ) with allegedly making false statements in connection with the IRS’s Streamlined Domestic Offshore Program (SDOP). The former CPA is now a fugitive, living since 2016 in a country that has no extradition treaty with the United States. The allegations in the Booker indictment [U.S. v. Brian Nelson Booker, 19 Cr. 60152 (S.D. Fla.)] should alarm anyone who has participated in the submission of a false streamlined disclosure, and it is an unfortunate reminder of the need for tax advisors to be vigilant when making assertions of nonwillfulness before the IRS.

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Claude M. Millman has been recognized by City & State NY at the Law Power 100 Reception for his election to the 2020 Law Power 100 list

City and State notes the list represents “New York’s 100 most influential lawyers . . . based on their achievements, track record and sway in political and policy matters.” The list describes Mr. Millman as a “seasoned attorney who appears regularly on lists of top lawyers” who “focuses on commercial civil litigation” and “has also represented contractors, including nonprofits, doing business with New York City and state.”

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Robert Russell participated in the panel entitled "Outbound Tax Developments," at the Federal Bar Association's 2020 Tax Law Conference

The TCJA made significant changes to how income of controlled foreign corporations is taxed. The operation of the new Global Intangible Low-Taxed Income (GILTI) continues to be molded as guidance is released related to foreign tax credits, previously taxed earnings and profits and foreign-derived intangible income.

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Michael Sardar participated in the panel entitled "When A Civil Audit Turns: Navigating An Audit When The Mistakes Are Not So Unintentional," at the Federal Bar Association's 2020 Tax Law Conference

Tax practitioners, even those who operate primarily in the civil space, should understand the procedures of criminal investigations and the warning signs (both from the client and the government) that a criminal referral is looming. This panel discussed issues that have the potential to influence an I.R.S. examiner’s decision to refer an audit for criminal investigation and offered practitioners tips to navigate those issues, either to avoid referral or to manage the process after a case turns criminal. This panel offered useful insights from both the civil and the criminal tax practitioner perspective.

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