IRS Provides Updated Voluntary Disclosure Practice Guidance After Closure of OVDP

ByJustin Hughes

On November 20, 2018, the IRS issued a memo on “Updated Voluntary Disclosure Practice” (the “Memo”). The Memo sets forth guidance for both domestic and offshore related voluntary disclosures after the recent closure of the Offshore Voluntary Disclosure Program (“OVDP”). The Memo is available here. Why is this guidance important? OVDP was the specifically designed…

Requirements For NOL Carryforward Utilization Surviving Scrutiny in IRS Examination
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Requirements For NOL Carryforward Utilization Surviving Scrutiny in IRS Examination

ByJustin Hughes

Joe and Mary operate a closely held business that generates a net operating loss in 2005 and 2007. The net operating loss from 2005 and 2007 are carried forward and are used to offset business income on Joe and Mary’s 2015 tax return. Joe and Mary’s 2015 tax return is selected by the IRS for…