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.
Penalties
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.
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.
IRS expands relief from underpayment penalty
The IRS announced that it is lowering from 85% to 80% the amount taxpayers are required to have paid in order to escape an underpayment of estimated income tax penalty for 2018.
First-year challenges of TCJA implementation require broader penalty relief
Despite generally lower tax bills, many taxpayers are seeing smaller-than-expected refunds — or no refunds at all. And some taxpayers are now subject to underwithholding penalties, despite limited relief from the IRS.
IRS can assess restitution for aiding tax evasion
The IRS can assess restitution that a taxpayer was ordered to pay as part of his sentence for violating Sec. 7201.
IRS finalizes tax preparer due-diligence regs.
The IRS issued final regulations on the penalty that applies to tax return preparers who fail to exercise due diligence in preparing returns for taxpayers who are claiming head-of-household filing status, the earned income tax credit, the child tax credit, the additional child tax credit, or the American opportunity tax credit.
Is your client the subject of an FBAR examination?
This article discusses a few key things practitioners should know about FBAR cases.
Some individual taxpayers get relief from underpayment penalty
The relief applies to individuals whose tax withheld and estimated tax payments equal at least 85% of the tax shown on their 2018 tax return.
Actor’s failure to document financial condition dooms offer in compromise
It was not an abuse of discretion for an IRS settlement officer to reject an offer in compromise where the taxpayer failed to document his assets or financial condition.
Resolving federal tax liabilities
This article explains debt resolution methods, how tax practitioners can assist taxpayers in the process of resolving a liability, and how taxpayers can administratively appeal adverse IRS collection determinations.
Negotiation with collections officer is not administrative proceeding
The IRS abused its discretion in failing to consider the taxpayers’ proposed offer in compromise, installment agreement request, and economic hardship claim.
Avoiding an accuracy-related penalty through the reasonable-cause exception
By knowing the factors courts consider in determining whether a taxpayer meets the requirements for the reasonable-cause exception, and how the courts have applied the factors, tax advisers can help their clients properly mount a defense to an accuracy-related penalty.
Tax preparer due diligence rules are finalized
The IRS issued final regulations on the penalty that applies to tax return preparers who fail to exercise due diligence in preparing returns for taxpayers who are claiming head-of-household filing status, the earned income tax credit, the child tax credit, the additional child tax credit, or the American opportunity tax credit.
Cryptocurrency: Compliance challenges and IRS enforcement
This item discusses some key U.S. tax implications and unanswered questions of cryptocurrencies and identifies possible avenues of relief for taxpayers with unreported income or assets connected to cryptocurrency.
IRS gives taxpayers penalty and late-election relief for Sec. 965 transition tax
The IRS announced relief from late-payment penalties and that it will allow late elections for taxpayers subject to the new Sec. 965 transition tax on deemed repatriated foreign earnings.
Failure to update penalty regulation costs IRS
The failure to update the regulations to reflect a statutory increase in the FBAR penalty amount prevents the IRS from assessing the full statutory amount of the penalty.
First-time abatement: Procedure and case law updates
An automated process for first-time abatements could ensure consistent application of relief for taxpayers.
