US v. Marin, 18 CV 9307 (VB) (US Dist. NY Jan. 22, 2020): IRS allowed to proceed with claims for unpaid estate tax

The government’s claim to foreclose its federal tax liens, for an order of judicial sale of the estate’s properties, and to appoint a receiver to operate and liquidate the properties was allowed to proceed. The estate argued that the probate exception to federal jurisdiction resulted in the court not having jurisdiction over the foreclosure claim. … Continue reading US v. Marin, 18 CV 9307 (VB) (US Dist. NY Jan. 22, 2020): IRS allowed to proceed with claims for unpaid estate tax

Rev. Proc 2020-8: Form 1023 – application for tax exempt status under Section 501(c)(3) must be filed electronically

The IRS has released guidance in Rev. Proc 2020-8 that requires electronic submissions of Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code. The guidance provides a 90-day transition relief period, during which paper Form 1023 applications will be accepted. This revenue procedure also modifies language related to the … Continue reading Rev. Proc 2020-8: Form 1023 – application for tax exempt status under Section 501(c)(3) must be filed electronically

IRS announces that it is taking the next step on abusive micro-captive transactions; nearly 80 percent accept settlement, 12 new audit teams established

The Internal Revenue Service announced the overwhelming acceptance of a time-limited settlement offer made to certain taxpayers under audit who participated in abusive micro-captive insurance transactions. Nearly 80% of taxpayers who received offer letters elected to accept the settlement terms. In addition, the IRS is establishing 12 new examination teams that are expected to open … Continue reading IRS announces that it is taking the next step on abusive micro-captive transactions; nearly 80 percent accept settlement, 12 new audit teams established

FPA Smartbrief: Shared Experiences Can Build Better Client Relationships

How key pieces of technology can boost business efficiency Focusing on the best way to leverage key pieces of technology can help advisers build more efficient and productive businesses, writes consultant Charesse Hagan. In this post, she outlines seven tech systems that can make a big difference in streamlining your workflow. FPA Practice Management Blog (1/23)  Opinion: Contrarian … Continue reading FPA Smartbrief: Shared Experiences Can Build Better Client Relationships

IRS Tax Practice Unit on Tax Home for Purposes of IRC Section 911

The IRS has published a tax practice unit on the determination of a tax home for purposes of Code Section 911, dealing with US citizens or residents living abroad. The summary is as follows: This Unit supersedes the 12/15/14 Unit with the same title.  This Unit discusses the factors to be considered in determining an … Continue reading IRS Tax Practice Unit on Tax Home for Purposes of IRC Section 911

IRS Tax Practice Unit on Source of Income for Nonresident Alien Individuals

The IRS has published a tax practice unit on source of income for nonresident aliens. The summary is as follows: NOTE: This Practice Unit was updated to incorporate changes due to the Tax Cuts and Jobs Act for tax years beginning after 12/31/2017 and supersedes the 05/12/16 Unit with the same title. Source of income … Continue reading IRS Tax Practice Unit on Source of Income for Nonresident Alien Individuals

IRS outlines new tax law effect on tax exempt organizations

The Internal Revenue Service has released a news released notifying tax-exempt organizations about recent tax law changes that might affect them. The Taxpayer Certainty and Disaster Tax Relief Act, passed on December 20, 2019, includes several provisions that may apply to tax-exempt organizations' current and previous tax years. Repeal of "parking lot tax" on exempt … Continue reading IRS outlines new tax law effect on tax exempt organizations