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tax Advice Archive

Statutes of Limitations and the Substitute for Return Procedures

TweetShareSharePin0 Shares We have written quite a few blog posts on the substitute for return (SFR) process but not one specifically addressing the statute of limitations regarding the returns prepared using this process.  Guest blogger Michelle Drumbl wrote about the procedures involved in preparing these returns. Guest blogger Jeffrey Sklarz wrote a post on the

Early sunset of the employee retention credit gets penalty relief

TweetShareSharePin0 Shares Employers that received an advance payment of the employee retention credit (ERC) or reduced their employment tax deposits in anticipation of receiving the ERC for the fourth calendar quarter of 2021 may repay or deposit the taxes without penalty under guidance issued Monday by the IRS (Notice 2021-65). The guidance became necessary when

AICPA tax advocacy gets results in 2021

TweetShareSharePin0 Shares Pandemic-related concerns, natural disasters, and new tax laws were among the many challenges that faced tax practitioners and their clients in 2021. In this ever-evolving environment, the AICPA Tax Policy and Advocacy group worked with the AICPA Congressional Affairs group to represent the interests of practitioners and the public. The AICPA’s tax advocacy

E-signing for forms, tax compliance documents extended

TweetShareSharePin0 Shares In a pair of internal memos (NHQ-10-1121-0005 and NHQ-01-1121-0004), the IRS has extended until Oct. 31, 2023, procedures that allow taxpayers and their representatives to sign digitally or by an image of their signatures an array of forms and returns as well as certain compliance-interaction-related forms and documents. The memos also reapprove for

Throwing the Baby Out with the Bathwater – the Proposed Repeal of IRC § 6751(b) Supervisor Approval of Penalties

TweetShareSharePin0 Shares Avid readers of Procedurally Taxing know that we have been closely following the litigation over IRC § 6751(b) and the Graev line of cases.  This litigation has also received attention from Congress in the Build Back Better Act, H.R. 5376, in which § 138404 repeals this provision and replaces it with a toothless

Join the Annual PT Giving Tuesday Drive

TweetShareSharePin0 Shares 0 Flares Filament.io Made with Flare More Info“> 0 Flares × It’s that time of year for the annual Procedurally Taxing tradition (among other traditions such as April Fool’s, Taxatturkeys, etc.) in which we provide an update on the Center for Taxpayer Rights’ activities over
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