The IRS Office of Chief Counsel announced in Issue Number IR-2020-130 that it will be making a time-limited settlement offer to certain taxpayers with pending docketed Tax Court cases involving


Continue Reading IRS Offers Settlement to Syndicated Conservation Easement Investors with Cases Pending in U.S. Tax Court

On Sept. 18, 2019, Governor Gavin Newsom signed Assembly Bill No. 5 (AB 5) into law in California. The landmark legislation, which came into effect Jan. 1, 2020, promises to
Continue Reading AB 5, California’s Gig-Work Law, Could Mean Inconsistent Federal and State Tax Treatment for Workers

While the IRS has been cracking down on syndicated conservation easements for over ten years, earlier this year Chuck Rettig, the Commissioner of the IRS, announced several campaign areas upon
Continue Reading Syndicated Conservation Easements: Under New Fire as IRS Enforcement Action Increases

Campaign for Compliance

Last year the IRS announced a new campaign to target “Withholding and International Individual Compliance” regarding Forms 1042 and 1042-S. Those who make payments of certain U.S.-source
Continue Reading Now Is the Time to Consider Voluntary Disclosure: Advancement of the IRS Campaign on Withholding Tax Noncompliance for Forms 1042, 1042-S

On Nov. 29, 2018, the IRS released a memorandum with new procedures for all voluntary disclosures following the end of the Offshore Voluntary Disclosure Program (OVDP) on Sept. 28, 2018.
Continue Reading IRS Releases New Voluntary Disclosure Procedures for Post 9-28-2018 Offshore and Domestic Disclosures

The IRS announced that it will end the Offshore Voluntary Disclosure Program (OVDP), effective September 28, 2018.  The IRS is pressing taxpayers with undisclosed foreign accounts, entities and income to
Continue Reading IRS Announces it Will End the Offshore Voluntary Disclosure Program Effective September 28, 2018