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Federal Taxation

  • Coronavirus and Nonprofits: Cancellation of Fundraising Events and Membership Dues May Convert to Tax-Deductible Donations

    By:
    Eva Mruk, Susan Barossi, CPA , and Garrett M. Higgins
    |
    Jun 1, 2020
    In the wake of the coronavirus (COVID-19) pandemic, charitable organizations around the world have been forced to cancel or postpone their fundraising events. In addition, many charitable organizations have been advised to close their facilities and perform their operations virtually, if possible. As a result, nonprofits that collect membership dues, tuition, or fees can render limited or even no services in exchange.

  • New PTIN User Fee: IRS Announcement Despite Ongoing Remand Litigation

    By:
    Frank G. Colella, Esq, LLM, CPA
    |
    Jun 1, 2020
    The IRS recently announced its intention to reimpose a practitioner tax identification number (PTIN) user fee for the 2020 tax season. The proposed regulation requires tax practitioners to pay $21 (plus a vendor fee) to obtain or renew their PTINs.

  • COVID-19 Emergency Tax Postponement Relief: The IRS Expands Its Scope

    By:
    Kevin Matz, JD, Esq., CPA, LLM
    |
    May 1, 2020
    On Apr. 9, 2020, as a further response to COVID-19, the U.S. Treasury Department and the IRS issued Notice 2020-23, which significantly expanded the scope of the emergency tax postponement relief. The relief granted by the new notice covers taxpayers who have an IRS tax filing or payment deadline between Apr. 1 and Jul. 15, 2020.

  • Estate Planning for Founders and Investors in Venture-backed Companies: Transfers of Qualified Small Business Stock by Gift

    By:
    Michael S. Arlein and Brian M. Sweet
    |
    May 1, 2020
    Congress first enacted IRC section 1202 in 1993 to encourage investment in specific types of small businesses by providing an exclusion of certain gain from the sale or exchange of qualified small business stock (QSBS). The original benefits of IRC section 1202 attracted moderate attention, but those benefits were significantly enhanced in subsequent decades, most notably under the Small Business and Jobs Act of 2010.

  • Penalty Avoidance: When Can Taxpayers Rely on Their Advisors?

    By:
    Ellen S. Brody, JD, Esq., CPA and Menahem M. Grossman, Esq.
    |
    May 1, 2020
    The IRC imposes various penalties on taxpayers who fail to comply with the obligations it sets forth for them. However, taxpayers can often avoid penalties if they can prove that their failure was due to reasonable cause and that they acted in good faith [IRC section 6664(c)(1)].

  • IRC Section 1202 Ignites Investor Interest

    By:
    Amy Bloom, CPA
    |
    Apr 1, 2020
    Alan Patricof, a vanguard in the venture capital industry, was instrumental in the enactment of IRC section 1202 as part of the Revenue Reconciliation Act of 1993 in order to encourage investment in small businesses. IRC section 1202 only applies to stock in C corporations, and initially it did not receive a lot of attention. Since its enactment, though, it has undergone several changes. The 2017 Tax Cuts and Jobs Act (TCJA), however, reduced the corporate tax rate from 35% to 21%, making operating as a C corporation more attractive to investors.

  • The IRS’s Offshore Voluntary Disclosure Program Has Ended—Now What?

    By:
    Christopher M. Ferguson
    |
    Apr 1, 2020

    On Sep. 28, 2018, the IRS’s Offshore Voluntary Disclosure Program (OVDP) came to an end; however, offshore tax and reporting noncompliance persists in today’s increasingly global economy. Tax advisors are still helping clients who have been—or continue to be—noncompliant with their offshore tax and reporting obligations. This Q&A addresses some of the common issues that taxpayers and their advisors are dealing with in a post-OVDP world.
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