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Tax Blawg

Tax Talk for Tax Pros

Introduction

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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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 September 8, the Texas Society of Certified Public Accountants added to this chorus with a comment letter to Treasury and ...

Categories: Tax Legislation

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 ...

Categories: COVID-19, Tax Relief

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 ...

Have you ever played darts?  Where the dart hits the board is very important to your score, but some rookies are happy if their dart hits the board at all.  That would be a fair characterization of The Inspector General for Tax Administration’s (“TIGTA”) January 21, 2020 report entitled “IRS Should Better Identify Noncompliant Exempt Orgs.”

In this report, TIGTA is very much like a rookie darts player, who declares himself a winner because his first dart hit the board.  In this regard, the Report is accurate about one thing:  the IRS does have problems identifying non-compliant ...

As the legal and tax landscape continue to be shaped by COVID-19, the Chamberlain Tax Planning & Business Transactions Team is diligently reviewing and analyzing the newest legislation and guidance. We have prepared the below summary of certain FAQs recently issued by the IRS regarding the tax credits available under the Families First Coronavirus Response Act ("FFCRA") and the Coronavirus Aid, Relief, and Economic Security Act (the "CARES Act"). Given the expedited nature in which this new legislation was passed, new guidance may continue to be issued in the future, which may ...

Categories: COVID-19, Tax Relief

COVID-19 is a public health crisis that has already had a profound impact on the U.S. economy. Businesses and individuals are struggling to adapt to restrictions imposed by federal, state and local governments in an attempt to "flatten the curve" and limit the consequences on public health. Several major laws were recently enacted to help partially offset the economic effects of this crisis and hopefully put businesses and the economy in a position to hit-the-ground running once this time has passed.

The Chamberlain Tax Planning & Business Transactions Team has prepared this ...

The Inspector General for Tax Administration, TIGTA, is in the news regularly.  In addition to tracking down misbehaving IRS employees and misbehaving representatives, an important role of this organization seems to be examining every aspect of the operation of the Internal Revenue Service about which it can publish a critical report.  Lately, it seems that TIGTA has been publishing an average of one a week, virtually all of which have been critical of the performance of the Internal Revenue Service.  Two of my favorites, however, deserve some close examination and cause this writer to ...

This must-attend seminar will help ensure that you are as ready as the IRS for 2014. Hosted by Best Lawyers-ranked Tier One taxation law firm Chamberlain, Hrdlicka, White, Williams & Aughtry, the event will feature presentations by Patrick Jankowski, CCR, Vice President, Research, Greater Houston Partnership, and more than 14 experts from Chamberlain Hrdlicka’s labor, transactional, planning, and tax controversy practices. Attendees can earn CLE/CPE/CFP credit.

December 5, 2013

Houston Marriott Westchase

Houston, Texas

Click here for more information

This must-attend seminar will help ensure that you are as ready as the IRS for 2014. Hosted by Best Lawyers-ranked Tier One taxation law firm Chamberlain, Hrdlicka, White, Williams & Aughtry, the event will feature presentations by named shareholder David Aughtry, a former IRS trial attorney and the firm’s leading tax litigator for nearly 30 years, and 15 other experts from Chamberlain Hrdlicka’s labor, transactional, planning and tax controversy practices. Attendees can earn CLE/CPE/CFP credit.

Wednesday, November 13, 2013

Cobb Galleria Centre

Atlanta, Georgia

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