When multiple entities have a relationship with a worker, the determination of which entity is the
“employer” can have significant additional tax consequences.
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TOPICS
IRS Practice & Procedure
Appropriations bill targets IRS conduct
The 2017 appropriations bill passed by Congress includes $11.2 billion for IRS operations and enforcement. But it also includes specific directives prohibiting certain IRS conduct.
Employment tax enforcement is trending
Practitioners should have a basic awareness of some of the unique tools the government uses to enforce employment tax laws.
The required-records doctrine and the Fifth Amendment
This item discusses the Fifth Amendment protection
generally in tax practice and one of its important exceptions—the required-records doctrine.
Tax preparer mistakes: Taxpayer penalties and the tax treatment of indemnity payments
Relying on a tax professional does not guarantee that the penalty will be removed for a taxpayer.
Departing aliens and the sailing permit
It is important to understand compliance requirements should the IRS begin using the sailing permit to aid its collection efforts.
IRS reopens PTIN registration system
The system had been down since early June, after a federal court held that the IRS cannot charge a PTIN fee.
Employment taxes: Beware civil and criminal penalties
The government can impose a 100% trust fund recovery penalty on “responsible persons” who were required to pay over the money or who controlled the funds.
Federal court strikes down PTIN fees, upholds PTINs
The D.C. District Court held that the IRS has the authority to require preparers to use preparer tax identification numbers (PTINs) but that it cannot charge fees for issuing PTINs.
IRS to accept only electronic payments for ruling requests
The IRS announced that it will no longer accept checks in payment for ruling requests beginning June 15.
Office of Professional Responsibility cannot investigate disbarred tax preparer
The IRS OPR has no authority or jurisdiction over a disbarred attorney/tax preparer or his tax preparation practice and cannot regulate his provision of tax advice, a federal district court in Nevada has held.
Excise tax recent developments: Failure to maintain proper documentation leads to taxpayer losses
Taxpayers engaging in transactions involving federal excise taxes should be mindful of the documentation requirements.
IRS reports sharp drop in enforcement activity in 2016
The IRS reported several large drops in its enforcement activities in fiscal year 2016, compared to the prior year.
The trust fund recovery penalty and LLCs
A responsible person may be subject to the TFRP if it can be shown he or she willfully failed to pay the trust fund taxes due.
IRS issues rules making pilot SB/SE Fast Track Settlement program permanent
The IRS has formally established the Small Business/Self Employed Fast Track Settlement program and modified its rules.
Infrastructure spending and excise tax: It’s about to get a lot more complicated
This article discusses how excise tax changes may affect your business and what you can do to ensure tax compliance and avoid potential penalties.
President’s budget includes tax proposals and regulation of return preparers
President Donald Trump’s proposed FY 2018 budget includes a new proposal to give the IRS authority to regulate paid tax return preparers.
IRS notice response tips everyone should know
This column discusses IRS notices and how taxpayers should react to them.
Leveraged spinoffs removed from IRS no-ruling list
The IRS says it will again issue rulings on corporate leveraged spinoff transactions.
New IRS rules, no increased funding in appropriations bill
The 2017 appropriations bill passed by Congress includes $11.2 billion for IRS operations and enforcement. But it also includes specific directives prohibiting certain IRS conduct.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
