Welcome to TaxBlawg, a resource from Chamberlain Hrdlicka for news and analysis of current legal issues facing tax practitioners. Although blawg.com identifies nearly 1,400 active “blawgs,” including 20+ blawgs related to taxation and estate planning, the needs of tax professionals have received surprisingly little attention.
The Wall Street Journal's Tax Blog gives “tips and advice for filers,” and Paul Caron’s legendary TaxProf Blog is an excellent clearinghouse for academic and policy-oriented news. Yet, tax practitioners still lack a dedicated resource to call their own. For those intrepid souls, we offer TaxBlawg, a forum of tax talk for tax pros.
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- Posts by Peter A. LowyShareholder
Peter A. Lowy, a shareholder in Chamberlain Hrdlicka’s Houston office, is best known for his tax controversy work and deep experience in the energy sector. He also advises corporations and other taxpayers in a broad spectrum of ...
As discussed in an earlier Chamberlain Tax Blawg, on August 28 Treasury issued Notice 2020-65 which defers the due date for withholding, deposit and payment of employee-side taxes imposed under Section 3101(a) (FICA) and corresponding taxes under Section 3201 (RRT). Since the issuance of this Notice, there has been much commentary – in addition to consternation and hand-wringing on the part of clients – about a multitude of issues the Notice implicates.
On Friday, in response to an August 8, 2020 Presidential Memorandum, Treasury issued Notice 2020-65 which defers the due date for withholding, deposit and payment of employee-side taxes imposed under Section 3101(a) (FICA) and corresponding taxes under Section 3201 (RRT). This deferral is effective September 1!
No doubt this Notice will be the subject of fierce political debate. The day of the Notice’s release, Congressman Don Beyer of Virginia fired a first shot across the bow. In a press release, the Congressman accused the deferral of being a “gimmick” that “could hit ...
Last week, the Fifth Circuit in Matter of Diaz invalided a bankruptcy court rule that would have required that taxpayers make available to creditors any current or projected tax refund in excess of $2,000. Docket No. 19-50982 (5th Cir., Aug. 26, 2020).
The perfect storm is developing for this issue to affect a growing number of taxpayers. Due to the economic downturn during the Coronavirus pandemic, a record number of bankruptcies is anticipated. Also expected is a potentially unprecedented number of tax refunds as a result of the Coronavirus Aid, Relief, and Economic Security ...
On August 24, the IRS issued an internal memorandum that impacts when taxpayers may obtain IRS Appeals Conferences if their issues are designated for litigation. As background, the IRS has a long-standing policy of permitting taxpayers an administrative-level review of audit adjustments by referring matters to its Office of Appeals. For decades, this review process was discretionary for the IRS to offer. It was a matter of administrative grace. No longer.
Enter The Taxpayer First Act
In July 2019, Congress enacted The Taxpayer First Act which codified the Appeals Office (with a new ...