In an effort to extend additional relief to opportunity zones in light of the COVID-19 pandemic, the IRS issued Notice 2020-39 on Jun. 4, 2020. It provides very significant relief for qualified opportunity funds (QOF) and their investors.

America is the most litigious society in the world, and few thoughts strike more fear into the hearts of ordinary people than a protracted lawsuit and—even worse—enforcement of a monetary judgment. Outside of the nation’s capital, New York is home to the most lawyers per capita, so the dangers of litigation loom larger in that state than almost anywhere else.

Even if you’re not a classic film buff, you may know of the “damsel in distress” film genre from the era of silent movies: A villain decked out in a curlicue mustache kidnaps a pretty woman—the significant other of his archenemy—and ties her to the railroad tracks. As the train comes clickety-clacking down the track, the hero, a handsome man on a white horse, rescues the damsel in the nick of time. He also captures the villain and saves the day.

With the recent passage of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, Congress enacted many tax provisions intended to lessen the economic harm caused by the coronavirus (COVID-19) outbreak. Among those changes was a fix for an issue known as the “retail glitch,” which arose from the last major piece of tax legislation, the Tax Cuts and Jobs Act (TCJA).

In April 2020, the IRS quietly updated Form 14457. Previously called the “Offshore Voluntary Disclosure Letter,” the form’s name was changed to “Voluntary Disclosure Practice Preclearance Request and Application.” It had been used in conjunction with the Offshore Voluntary Disclosure Program (OVDP) that ended Sept. 28, 2018.

In a typical case, the IRS will audit federal tax issues, and when audit changes are made, it will notify New York State. With little additional work, New York will bill the taxpayer the amount of additional state tax resulting from these federal tax changes. Taxpayers are required to report the IRS audit changes on a New York State amended return within 90 days of the IRS notification, regardless of whether they receive a bill from the state.