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IRS Continues to Issue Guidance for International Taxpayers in Light of COVID-19

IRS Continues to Issue Guidance for International Taxpayers in Light of COVID-19

As COVID-19 continues to impact daily life, the IRS has published guidance to address the tax consequences for certain international taxpayers. Recent travel restrictions could require individuals to remain in locations longer than expected, resulting in a changed tax status. In order to mitigate this result, the IRS provided relief provisions to put certain affected persons in the same U.S. tax position they would have been in, but for the COVID-19 crisis.

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Michael Sardar presented a webinar entitled "Penalty Standards for the Taxpayer and the Preparer" for The CPA Academy on June 11, 2020

When the IRS audits a taxpayer and determines that additional tax is due, the taxpayer may be subject to penalties in addition to the tax due. Further, the tax practitioner involved in preparing that tax return may also be subject to penalties. This course covered the standards applicable to both the taxpayer and tax practitioner when the IRS determines whether to impose penalties. Mr. Sardar reviewed the relevant standards, including reasonable basis, substantial authority, and how to make adequate disclosure.  Knowing and applying theses standards will help the practitioner and taxpayer avoid IRS penalties.

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Paycheck Protection Program Flexibility Act passed June 5, 2020

The Paycheck Protection Program Flexibility Act of 2020 (“PPPFA”) was signed into law by President Trump on June 5, 2020. The PPPFA intends to provide flexibility for businesses making use of Paycheck Protection Program (“PPP”) funds by:

  1. extending the “covered period;”
  2. increasing the amount of loan forgiveness that may be attributable to non-payroll costs;
  3. extending the date by which employers must restore full-time employee (“FTE”) levels;
  4. creating a new safe harbor for inability to restore FTE levels;
  5. extending the loan repayment period to five years; and
  6. deferring payroll tax.  
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Nicholas S. Bahnsen moderated an American Bar Association panel entitled "Ethical Obligations and COVID19: What Tax Practitioners Need to Know" on June 4, 2020

What should we be on the lookout for to ensure we are not helping our clients participate in or become the victim of fraud considering the CARES Act? How should practitioners ensure we are meeting both IRS and court deadlines? How should we ensure we are meeting our ethical obligations to communicate with our clients? Nicholas S. Bahnsen moderated a panel discussing these timely issues. 

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Caroline Ciraolo contributed to ABA Tax Section Comments on proposed changes to Tax Court Rule 24

Caroline Ciraolo made substantive contributions to the American Bar Association Taxation Section Comments on the proposed changes to Tax Court Rule 24. The comments were formally submitted to Chief Judge Foley of the U.S. Tax Court on June 1, 2020.

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Caroline Ciraolo Featured on ACA TaxCast on May 31, 2020

Caroline Ciraolo was interviewed for the American Citizens Abroad (ACA) TaxCast podcast. Part 1 of her interview was posted May 15, 2020, and Part 2 was posted on May 31, 2020. During Part 2 of the program, Ms. Ciraolo takes a "deeper dive" into the types of tax professionals and government officials that may play a role in a client’s tax matters, the nature and risks of an “eggshell” audit, the scope of applicable privileges, best practices for vetting clients and managing an examination or investigation, and much more. 

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Robert M. Russell quoted in Bloomberg Tax article entitled "IRS Fixes to Foreign Tax Credit Rules Could Boost New Virus Perk"

In a recent Bloomberg Tax article by Siri Bulusu entitled "IRS Fixes to Foreign Tax Credit Rules Could Boost New Virus Perk," Robert M. Russell discussed how benefits, such as a net operating loss carry back provision, restored in response to the COVID-19 crisis could affect and interact with prior deductions and perks. 

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Megan Brackney presented a webinar entitled "IRS Summons and Other Methods of Obtaining Taxpayer Information, Enforcement, and Defenses" for Celesq Attorneys Ed Center, on May 21, 2020

The IRS has several methods for obtaining information about taxpayers. This program discussed the IRS’s methods of obtaining information, focusing primarily on the IRS’s summons authority, including the scope of that authority, taxpayer’s rights and privileges, summons enforcement litigation, and the attorney’s ethical obligations when responding to IRS requests for information under Circular 230.

 

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Paul Butler quoted in Tax Notes article entitled "Work-From-Home Technology Comes With New Privilege Concerns"

In a recent Tax Notes article by Nathan J. Richman entitled “Work-From-Home Technology Comes With New Privilege Concerns," Paul Butler discussed concerns about how to safeguard attorney-client privilege and protect the work product doctrine when using videoconferencing and other new technological tools that tax professionals are relying on during the coronavirus pandemic.

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Caroline Ciraolo participated in two-part series by Tax Analysts regarding IRS voluntary disclosure practice, revised Form 14457, and detailed guidance issued on May 13 and 14, 2020

On May 13 and 14, 2020, Caroline Ciraolo sat down with Tax Notes to discuss the revised Form 14457 and new guidance on the IRS voluntary disclosure practice in a two-part series. 

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