Legacy Advisors

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Your Offshore Voluntary Disclosure May Be Long Over but the IRS May Be Looking at Your Ongoing Tax Compliance

By Barbara T. Kaplan, Jared E. Dwyer, Michelle Ferreira, Scott E. Fink, Courtney A. Hopley, Jennifer A. Vincent & Shira Peleg

July 31, 2020

In July 2019 the IRS identified post offshore voluntary disclosure program (OVDP) compliance as a campaign. The purpose of the campaign is to pursue those OVDP participants who fail to remain compliant with their foreign income and asset reporting requirements. The campaign said that the IRS would address this tax noncompliance through soft letters and examinations. OVDP participants have recently received such soft letters. Continue reading the full GT Alert, “Your Offshore Voluntary Disclosure …

Legacy Advisors

Protecting Your Potential Tax Refund Should the Affordable Care Act’s Individual Mandate Be Determined Unconstitutional

By Barbara T. Kaplan

July 29, 2020

The U.S. Supreme Court has taken up the case of whether the Patient Protection and Affordable Care Act (ACA)’s individual mandate is unconstitutional. A decision on this issue is likely not to occur until next year but protecting a possible tax refund cannot wait. A claim for a tax refund must be made no later than three years from the filing of the income tax return in question or the refund will be barred. Read…

Legacy Advisors

Main Street Loans to Be Extended to Nonprofits

By Claire Arritola & Harry J. Friedman

July 23, 2020

On July 17, 2020, the Board of Governors of the Federal Reserve System (Federal Reserve) announced the terms of an expansion of the Main Street Lending Program to include loan facilities that would allow for nonprofit borrowers. The Main Street Lending Program opened on June 15, 2020, and is meant to increase access to capital for small- and medium-sized businesses that were in sound financial condition before the onset of the Coronavirus Disease 2019 (COVID-19)…

Legacy Advisors

IRS Audit and Investigation Priorities Now That the IRS Is Back in Business

By Barbara T. Kaplan

July 14, 2020

The Coronavirus Disease 2019 (COVID-19) pandemic caused the closure of Internal Revenue Service offices and service centers nationwide and the plummeting of new tax examinations. Although certain functions and ongoing cases within the IRS continued during this period, many did not, and new examinations of tax returns and enforced collection activity were put on hold under the People First Initiative. But the IRS is reopening, and taxpayers can and should expect that the agency…

Legacy Advisors

Barbara Kaplan Quoted in Law360 article, ‘International Tax Cases to Watch in the 2nd Half of 2020’

By Greenberg Traurig

July 14, 2020

Greenberg Traurig Global Tax Practice Co-Chair Barbara T. Kaplan comments on FBAR (Report of Foreign Bank and Financial Accounts) penalty disputes, in an article published July 10 by Law360. Read the full article, “International Tax Cases to Watch in the 2nd Half of 2020,” (subscription required).…

Legacy Advisors

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

By Barbara T. Kaplan, Josh Prywes, Michelle Ferreira, Scott E. Fink, Courtney A. Hopley, Shira Peleg & Jennifer A. Vincent

June 26, 2020

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 such conservation easement transactions, offering finality to the affected taxpayers. The settlement offers do not address those cases that are currently pending in Examination or IRS Appeals. Read the full GT Alert, “IRS Offers Settlement to Syndicated Conservation Easement Investors with Cases Pending in …

Legacy Advisors

IRS Issues Proposed Regulations on Excess Nonprofit Executive Compensation

By Harry J. Friedman & Claire Arritola

June 25, 2020

On June 5, 2020, the IRS issued proposed Treasury Regulations under section 4960 of the Internal Revenue Code of 1986, as amended (the Code). Background Section 4960 was added to the Code in 2017 as part of the Tax Cuts and Jobs Act. Section 4960 generally provides that if certain tax-exempt organizations (an “applicable tax-exempt organization” or “ATEO”) pay remuneration to certain employees (“covered employees”) in excess of $1,000,000 or an excess parachute payment, the…

Legacy Advisors

IRS Provides COVID-19 Relief for Qualified Opportunity Funds and Their Investors

By Lawrence H. Brenman, James O. Lang, Erez I. Tucner & Brian Gaudet

June 24, 2020

On June 5, 2020, the Internal Revenue Service (IRS) issued Notice 2020-39 providing relief for Qualified Opportunity Funds (QOFs) and their investors (QOF investors), and clarified previously issued relief to Qualified Opportunity Zone Businesses (QOZBs) affected by the president’s declarations of major disasters caused by the Coronavirus Disease 2019 (COVID-19) pandemic (which now apply in all 50 states, Washington, D.C., and five U.S. territories). This GT Alert summarizes the relief measures provided by the guidance. Continue …

Legacy Advisors

Greenberg Traurig Attorneys Jeffrey Mamorsky and Jonathan Sulds’ Pen ERISA Column in Pensions & Investments

By Greenberg Traurig

June 24, 2020

Whether the 5-4 Supreme Court decision in Thole vs. U.S. Bank on June 1 is “good news” for employers and will limit lawsuits by defined benefit participants, as some commentators have forecast, remains to be seen. From the perspective of advising fiduciaries how to discharge their responsibilities and avoid litigation, however, what the majority opinion means in practice should not be overlooked. Jeffrey Mamorsky and Jonathan Sulds delve into this issue in their column for …

Legacy Advisors

Coping with the Increase in 401(k) Cyberattacks and Fraudulent Plan Distributions

By Jeffrey D. Mamorsky

June 18, 2020

Plan sponsor employers and employees participating in 401(k) or other retirement plans should be aware of cybersecurity breaches and unauthorized plan distributions. Vigilance may be even more critical because of the March 2020 CARES Act legislation that permits early retirement distributions without penalty for plan participants affected by the Coronavirus Disease 2019 (COVID-19) pandemic. The heightened level of plan distributions coupled with the security risks associated with electronic communications and the “new normal” of working…

Legacy Advisors

Powered by GT Tax - A Greenberg Traurig Knowledge Product

Your Offshore Voluntary Disclosure May Be Long Over but the IRS May Be Looking at Your Ongoing Tax Compliance

Protecting Your Potential Tax Refund Should the Affordable Care Act’s Individual Mandate Be Determined Unconstitutional

Main Street Loans to Be Extended to Nonprofits

IRS Audit and Investigation Priorities Now That the IRS Is Back in Business

Barbara Kaplan Quoted in Law360 article, ‘International Tax Cases to Watch in the 2nd Half of 2020’

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

IRS Issues Proposed Regulations on Excess Nonprofit Executive Compensation

IRS Provides COVID-19 Relief for Qualified Opportunity Funds and Their Investors

Greenberg Traurig Attorneys Jeffrey Mamorsky and Jonathan Sulds’ Pen ERISA Column in Pensions & Investments

Coping with the Increase in 401(k) Cyberattacks and Fraudulent Plan Distributions

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