The IRS recently issued Revenue Procedure 2022-19, which permits S corporations to remedy certain inadvertent terminations of S corporation status and invalid elections without having to request a costly Private Letter Ruling. Previously, the IRS permitted such relief without a Private Letter Ruling in only two limited circumstances – (1) failing to timely file Form
IRS
Important Supreme Court Decision will Decide how Non-Willful FBAR Penalties are Calculated
By Ram Shastri & Reuben Muller on
This fall, the Supreme Court is set to hear an important case regarding the interpretation of the law that provides for penalties for failing to file an FBAR. The case will impact many taxpayers who have already been penalized and many more in the future.
In 1970, the Bank Secrecy Act was enacted to curb…
Newly Enhanced Estate Tax Portability Relief under Revenue Procedure 2022-32
By Matthew Turko on
Effective July 8, 2022, the IRS issued Revenue Procedure 2022-32 to supersede Revenue Procedure 2017-34 and now allow for a late estate tax exemption portability election to be made up to five (5) years from a deceased spouse’s death. Previously, this window was only two (2) years from the deceased spouse’s death. Revenue Procedure 2022-32…
Relief for Qualified Opportunity Funds & their Investors affected by the COVID-19 Pandemic
By Philip Hirschfeld on
The IRS recently issued Notice 2020-39, which offers relief to both qualified opportunity zone funds (“QOFs”) and persons seeking to invest in QOFs who are affected by the global COVID-19 pandemic.
Investors in QOFs who want to defer capital gains and receive other QOF tax benefits are required to invest in a QOF within 180…
IRS Extends Key Tax Deadlines for 1031 Tax Deferred Exchanges and Investments in Qualified Opportunity Funds
On April 9, 2020, the IRS extended certain additional key tax deadlines affecting payments from both individuals and businesses due to the impact of the COVID-19 pandemic. Notice 2020-23 expanded upon prior IRS guidance that extended the dates for taxpayers to file Federal tax returns and render tax payments by creating a general extension to…