IRS Announces Late Portability Election Relief for Eligible Estates

IRS Announces Automatic Late Portability Election Relief for Eligible Estates

On June 9, 2017 the Internal Revenue Service (the “IRS”) published Revenue Procedure 2017-34 (“Rev. Proc. 2017-34”) to announce a new simplified procedure for particular estates to obtain an extension of time to file a federal estate tax return and make a “late” portability election. First introduced into federal law […] Read more »

IRS Releases Notice 2016-66 To Further Contest Small Captive Structures

Estimated Read Time: 3.1 minutes. On November 1, 2016, the Internal Revenue Service released Notice 2016-66, identifying “micro-captive transactions” (including certain small captive insurance companies) as transactions of interest.  Involvement in such transactions can, under Treas. Reg. § 1.6011-4, necessitate heightened reporting requirements, both for participants and for their advisors.  […] Read more »

IRS Clarifies FBAR Penalty Assessment Amounts & Criteria for Agents

On May 13, 2015, the Internal Revenue Service issued SBSE-04-0515-0025, titled “Interim Guidance for Report of Foreign Bank and Financial Accounts (FBAR) Penalties.”  The issuance provides limitations for assessment of FBAR penalties under the vast majority of circumstances presented by taxpayers.  The issuance provides both clarity as to worst-case scenarios […] Read more »

Powers of Attorney & IRS FBAR Reference Guide

FBAR Filing and Powers of Attorney: The recently published “IRS Reference Guide on the Report of Foreign Bank and Financial Accounts (FBAR)” explains the purpose of the FBAR, who must file, and provides a host of definitions relating to the FBAR regulations. Perhaps most notably, the reference guide explains that […] Read more »