Late-filing penalties for foreign trust filings can be devastating to clients and a significant challenge to CPAs trying to explain or eliminate them.
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TOPICS / PROCEDURE
Collections, Liens & Levies
District Court lowers penalties for Form 3520 nonfiling to zero
The ruling provides guidance by a federal district court on the application of the civil penalties for unfiled Forms 3520 for foreign trusts.
IRS waives failure-to-deposit penalties during pandemic
The IRS is permitting eligible employers who pay qualifying wages to retain an amount of the payroll taxes equal to the amount of qualifying wages that they paid, rather than deposit them with the IRS.
IRS penalty relief available when approvals not timely
Tax Court decisions address the proof the IRS must provide to show proper supervisory approval was obtained to assert penalties.
Bounced check is not a payment
The IRS can apply levy proceeds to liabilities for any
tax year covered by the levy.
Foreign gifts: A common example of undisclosed foreign transactions
Here’s what may happen when a foreign gift has not been disclosed.
Centralized partnership audit regime: Appeals procedures
The IRS published two memoranda that clarify how it will implement the BBA procedures, including appeal rights.
Tax Court tackles supervisory approval of penalties
In three cases, the Tax Court addressed issues regarding the approval of penalties required by Sec. 6751(b)(1).
Relief procedures for certain people planning to renounce US citizenship
The procedures allow qualifying former U.S. citizens who have relinquished U.S. citizenship to comply with their U.S. income tax and reporting obligations without paying any unpaid taxes and penalties.
Information return penalties: How to avoid or contest them
This article discusses the information return filing requirements and associated penalties, how to avoid incurring the penalties, and how the penalties can be contested if they are imposed by the IRS.
IRS offers time-limited settlement on microcaptive insurance issues
The IRS announces a settlement initiative for abusive microcaptive insurance transactions.
Fraudulent intent lands CPA in hot water
A CPA taxpayer was found to have fraudulent intent
in various tax minimization schemes he engaged in.
Reliance on preparer is not reasonable cause for late filing
The advent of e-filing has not changed the rule that reliance on a preparer to file a return is not a reasonable cause for a taxpayer’s failure to file a timely return.
Substitute-for-returns procedure
Taxpayers who fail to file tax returns may receive assessments from an IRS-prepared substitute for return.
Underpayment penalty relief now automatic for eligible filers
Some taxpayers who paid 2018 underpayment penalties will receive refund checks because the penalties will be automatically waived for those who qualify, the IRS announced.
Final Sec. 6707A regulations on penalty for failing to disclose reportable transactions
The IRS issued final regulations under Sec. 6707A, which imposes a penalty on taxpayers who fail to disclose a reportable transaction on their tax returns.
Tax time travel: Securing relief from unforced errors, missed elections, and other mistakes
This item provides a quick overview of several tools available to taxpayers who have made mistakes.
Impact of Sec. 199A in computing substantial-understatement penalties
An erroneously claimed qualified business income deduction under Sec. 199A can expose a taxpayer
to a substantial underpayment penalty.
Don’t let clients get grounded by a tax debt
CPAs can advise clients on the proper measures to take to address delinquent taxes so the debt does not result in a passport revocation.
Final rules issued on penalty for nondisclosure of reportable transactions
The IRS issued final regulations under Sec. 6707A, which imposes a penalty on taxpayers who fail to disclose a reportable transaction on their tax returns.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
