By: Caroline Rule Journal of Tax Practice & Procedure Summer 2020 Edition Recent litigation has focused on the government’s new position that the $10,000 non-willful civil FBAR penalty applies per account listed on an non-willfully untimely-filed annual FBAR—a Report of Foreign Bank or Financial Accounts that must be filed
By Sidney Kess and Julie Welch The CPA Journal June 2020 Good times or bad, it is vital for investors to hold cash reserves. Federal deposit insurance provides an extra layer of comfort, so it is vital for CPA advisors to know the rules and be
Kostelanetz & Fink attorneys Yoram Keinan and Robert Russell were proud to volunteer for the IRS’s first-in-the-country Virtual Settlement Days with the University of Michigan Law School’s Low-Income Tax Clinic (LITC) on May 9 and May 12, 2020. The IRS held settlement conferences for 42 docketed U.S. Tax Court
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
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 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: extending the “covered period;” increasing the amount of
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. The Tax Section’s comments can
By Usman Mohammad The ABA Tax Times Vol. 39 No. 3 – Spring 2020 Puerto Rico, American Samoa, Guam, The United States Virgin Islands, The Northern Mariana Islands—these are all United States territories or possessions. Individuals born in these territories are deemed by law to be
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
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
