Publications Archives - Page 7 of 26

ABA Tax Section Important Civil Developments May 2021 Report

By Stephen A. Josey, Russell A.S. Wirth, et al. American Bar Association, Tax Section Civil & Criminal Tax Penalties Committee May 2021 Meeting The ABA Tax Section meets three time a year, and at each meeting the subcommittees of the Civil & Criminal Tax Penalties

The IRS’s Assessment Of Penalties On Substitute Forms 3520-A

By Megan L. Brackney Tax Notes International, Volume 102 Issue 3 Tax Notes Federal, Volume 171 Issue 3 April 19, 2021 In recent months, we have seen several clients being heavily penalized for purportedly late filing Form 3520-A, “Annual Information Return of Foreign Trust With

Playing Catch With A Hand-Grenade: How To Deal With An Unreported Foreign Bank Account In A Divorce

By Bryan C. Skarlatos and Caroline Rule Journal of the American Academy of Matrimonial Lawyers Volume 33 Issue 2 (2021) When it comes to unreported foreign bank accounts, there is good news and bad news. The good news is that a previously unreported foreign bank

Promoting Diversity, Inclusion, And Equality Through Pro Bono Service

By Lawrence (Larry) Sannicandro Tax Notes State Volume 100 (posted on April 5, 2021) In the wake of major social and racial change, many organizations are making a concerted effort to promote diversity, inclusiveness, and equality in the workplace. These efforts are commendable, but more

An E-Sign Of Changing Times: IRS Now Permits Online Filing Of Forms 2848 And 8821

By Dan Davidson and Destiny Reese PLI Chronicle March 2021 Issue Over 70% of federal tax filings in 2019—including almost 90% of individual income tax returns—were filed electronically. Yet, as tax practitioners know, many federal tax forms continue to require “wet” signatures. Even before the COVID-19

How To Delegate Payroll, Employee-Related Tax Filings, And Associated Employer Duties To A Professional Employer Organization

By Caroline Rule and Russell A.S. Wirth The CPA Journal February/March 2021 Issue Many small- to medium-size businesses struggle with the burdensome costs of administering payroll, employee-related federal and state tax requirements, and other employee benefits. A related group of companies that finds itself in this

Showing Us How To Get It Done: Nina Olson

By Caroline D. Ciraolo Pittsburgh Tax Review, University of Pittsburgh School of Law Volume 18 Issue 1 (Fall 2020) A Brilliant Mind. A Caring Heart. A Force of Nature. These are just some of the ways we have described our friend, our mentor, our champion: Nina

White Collar Criminal Investigations Slowing Down? Think Again…The Increase in Employment Tax Prosecutions

By Caroline D. Ciraolo The White Collar Crime Committee Newsletter, ABA Criminal Justice Section’s White Collar Crime Committee Winter/Spring 2021 The Internal Revenue Service (“IRS”) is responsible for nearly 96% of the gross revenue received on behalf of the United States. Employment taxes, including federal income

AMLA 2020: Sweeping New AML Laws Have Broad Impacts on All Financial Crimes

By Don Fort, Christopher M. Ferguson, and Olivia Renensland The White Collar Crime Committee Newsletter, published by the ABA Criminal Justice Section’s White Collar Crime Committee Winter/Spring 2021 On January 1, 2021, following House and Senate overrides of a presidential veto, the National Defense Authorization

PENALTIES—Reconsidering the Reasonable Cause Defense to Late-Filing Penalties and the Impact of the Service’s Clarification of the DIIRSP

By Lawrence Sannicandro Journal of Tax Practice & Procedure Winter 2020 Edition During the 2019 fiscal year, the Internal Revenue Service (“Service” or “IRS”) assessed more than 4.7 million late-filing penalties that cost taxpayers nearly $9.9 billion. These late-filing penalties account for an incredible 24%

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