Bryan C. Skarlatos quoted in Law360 Tax Authority article entitled "Pandemic Payment Program Will Add Nonfilers To IRS Rolls"
Bryan C. Skarlatos quoted in Law360 Tax Authority article entitled "Pandemic Payment Program Will Add Nonfilers To IRS Rolls," which explored the effects the coronavirus-related stimulus payments may have on the IRS’s ability to “to collect substantially more revenue in the future from individuals who had previously stayed below its radar.”
On March 30, the IRS Small Business/Self-Employed Division’s (“SBSE”) Director of Collection issued a Memorandum for All Collection Executives (the “Collection Memo”) ordering the implementation of a period of suspension of “most collection activities” by the IRS as part of the broader effort to provide temporary relief for taxpayers amid the COVID-19 pandemic. Under the guidance provided by the Collection Memo, taxpayers can expect most IRS collection activities to stop during the suspension period, which stretches from March 30, 2020 to July 15, 2020.
Megan Brackney presented a webinar entitled "The New IRS Fraud Enforcement Office: Enforcement & Consequences of Tax Fraud," for the CPA Academy, on April 7, 2020
Now is a good time to enhance your understanding of tax fraud and the IRS’s antifraud enforcement tools The IRS has created a new Fraud Enforcement Office to develop increased enforcement, both with criminal referrals from the field and additional civil fraud penalties. This webinar discussed the indicia of fraud, how the IRS identifies and proves fraud, and the civil and criminal consequences of tax fraud, and the relevant procedures.
The IRS has created a webpage on IRS.gov designed to answer taxpayer and business questions about stimulus payments and other guidance issued in response to the novel coronavirus pandemic. The webpage is being updated as needed to help individuals and businesses navigate the new guidance, obtain stimulus payments to which they are entitled and understand the new reporting and payment deadlines.
Caroline Rule Article on U.S. v Greenfield Selected for Inclusion in the March/April Magazine of the ABA General Practice Division
Caroline Rule’s article, “United States v. Greenfield: A Triumph of the Fifth Amendment’s Act of Production Privilege; or Confirmation that the Privilege Can Be Entirely Abrogated by Any Act of Congress, or Even by a Treasury Regulation?” published in The Tax Lawyer, Winter 2018 (71:2), has been selected for inclusion in the March/April magazine of the ABA General Practice Division, which will focus on “The Best of ABA Sections”--a compilation of some of the best articles published by the ABA’s sections, forums, and divisions.
In his more than two decades of experience in both the U.S. and Israel, Yoram Keinan has developed extensive experience with respect to the domestic and international taxation of financial products and institutions, and he’s been bringing that knowledge to classrooms at both his alma mater, the University of Michigan Law School, and Georgetown Law Center in a class that is again being offered at both schools, “Taxation of Financial Instruments and Transactions.”
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.
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.
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.
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).