TAXLITIGATOR – Tax Controversy (Civil & Criminal) Report

Since our Blog post earlier this week regarding the initial tax payment (but not filing deadline) relief announced by Treasury Secretary Steven Mnuchin, the government has gone further.  As particularly important for busy tax preparers, the normal tax payment and filing deadline of April 15, 2020 have now both been extended until July 15, 2020.  The Treasury Secretary’s tweet on this point referenced both the filing deadlines and payments, without a reference to the prior relief limitations of $1,000,000 for individuals and $10,000,000 for corporations.

While this blog post is an update on this filing deadline with commentary, as opposed to a comprehensive update on the quickly developing and substantial legislative tax relief, below are links to both state and federal resources related to tax relief from CalCPA and the AICPA.

As preparers take a breath for perhaps half a day as the deadline is extended, their next step will be to absorb the substantial tax and other relief provisions, much of which is administered on the shoulders of the IRS and other state tax agencies.

Many of the continuing education programs for tax attorneys and tax preparers over the last few years have been focused on understanding Tax Cuts and Jobs Act, and the Qualified Business Income Deduction in particular.  With the economic outlook temporarily turned on its head, the optimistic Qualified Business Income Deduction provisions take on a new light.  The focus for many taxpayers may now be on losses in 2020.  The latest proposed relief provisions are already considering Net Operating Loss limitations that were added to the Tax Cuts and Jobs Act.  Additionally, the Senate has remembered the relief provided after the economic and real estate crash in 2008 and 2009, when they supercharged the net operating losses and the ability to carry them back.  As the legislation is in flux, we will see where the specific relief provisions settle.  In summary, an initial glimpse of the legislative stimulus is that it provides some of the “best hits” from the last 20 years and may apply many of them at once.

CORY STIGILE – For more information please contact Cory Stigile – stigile@taxlitigator.com  Mr. Stigile is a principal at Hochman Salkin Toscher Perez P.C., a CPA licensed in California, the past-President of the Los Angeles Chapter of CalCPA and a Certified Specialist in Taxation Law by The State Bar of California, Board of Legal Specialization. Mr. Stigile specializes in tax controversies as well as tax, business, and international tax. His representation includes Federal and state controversy matters and tax litigation, including sensitive tax-related examinations and investigations for individuals, business enterprises, partnerships, limited liability companies, and corporations. His practice also includes complex civil tax examinations. Additional information is available at www.taxlitigator.com