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Identity Protection PIN Available to ALL Taxpayers in January

Beginning in January 2021, the IRS will allow all taxpayers who can properly verify his/her identity to obtain an Identity Protection PIN. An Identity Protection PIN (“IP PIN”) is a six-digit number assigned to a specific taxpayer to assist in preventing the misuse of a taxpayer’s social security number on fraudulent federal tax returns. Previously, only confirmed victims of identity theft who resolved his/her tax issues with the IRS were eligible for an IP PIN.

Eligibility

To be eligible for the IP PIN Opt-in Program, a taxpayer must pass a rigorous identity verification process. Spouses and dependents are eligible for an IP PIN if he/she can also pass the identity verification process.

How to get an IP PIN

In order to participate in the IP PIN Opt-in Program, a taxpayer may apply online, mail in Form 15227, or in certain circumstances, may make an in-person appointment.

Applying online

Taxpayers who apply online should use the “Get an IP PIN” tool on the IRS website. The taxpayer will need to create an account on IRS.gov if one has not already been created previously. When creating an account, the taxpayer should have the following readily accessible:

  • Email address
  • Social Security Number
  • Tax filing status and mailing address
  • One financial account number linked to the taxpayer’s name such as:
    • Credit card
    • Student Loan
    • Mortgage
    • Home Equity Line of Credit
    • Auto Loan
  • Mobile phone linked to the taxpayer’s name or the ability to receive an activation code by mail

Once logged in to the Get an IP Pin tool, the taxpayer’s IP PIN will be immediately displayed.

Applying by mail

Taxpayer’s whose income is $72,000 or less may complete Form 15227, Application for an Identity Protection Personal Identification Number. This Form may be mailed or faxed to the IRS and will be available in January 2021. After receipt, an IRS employee will call the taxpayer to verify his/her identity using a series of questions. If the taxpayer successfully verifies his/her identity, an IP PIN will be assigned for the following tax year. If a taxpayer chooses to file a Form 15227, caution should be used when the IRS agent calls to ensure the caller is not a scammer.

Applying in-person

For taxpayer’s who cannot verify his/her identity remotely or are ineligible to file Form 15227, an in-person appointment at a Taxpayer Assistance Center may be made. The taxpayer should take two forms of picture identification with them to the appointment. If the taxpayer successfully verifies his/her identity at the in-person appointment, the IRS will mail an IP PIN to him/her within three weeks.

Things to Know if an IP PIN is issued

Taxpayer’s should be aware of that IP PINs are only valid for one year. Each January, the taxpayer must obtain a new IP PIN. IP PINs must also be entered correctly on the federal tax return or the return may be rejected or delayed

For additional questions related to the identity theft and the IP PIN program, please contact BMD Tax Law Attorney Tracy Albanese at tlalbanese@bmdllc.com or (330) 253-9195.

Explosive Growth in Pot of Gold Opportunity for Bank (and Other) Cannabis Lenders Driving Erosion of the Barriers

Our original article on bank lending to the cannabis industry anticipated that the convergence of interest between banks and the cannabis industry would draw more and larger banks to the industry. Banks were awash in liquidity with limited deployment options, while bankable cannabis businesses had rapidly growing needs for more and lower cost credit. Since then, the pot of gold opportunity for banks to lend into the cannabis industry has grown exponentially due to a combination of market constraints on equity causing a dramatic shift to debt and the ever-increasing capital needs of one of the country’s fastest growing industries. At the same time, hurdles to entry of new banks are being systematically cleared as the yellow brick road to the cannabis industry’s access to the financial markets is being paved, brick by brick, by the progressively increasing number and size of banks that are now entering the market.

2021 EEOC Charge Statistics: Retaliation & Impact of Remote Work

The U.S. Equal Employment Opportunity Commission (EEOC) released its detailed information on workplace discrimination charges it received in 2021. Unsurprisingly, for the second year in a row, the total number of charges decreased as COVID-19 either shut down workplaces or disconnected employees from each other. In 2021, the agency received a total of approximately 61,000 workplace discrimination charges - the fewest in 25 years by a wide margin. For reference, the agency received over 67,000 charges in 2020, and averaged almost 90,000 charges per year over the previous 10 years.

Ohio’s Managed Care Overhaul Delayed – New Implementation Timeline

At the direction of Governor Mike DeWine, the Ohio Department of Medicaid (ODM) launched the Medicaid Managed Care Procurement process in 2019. ODM’s stated vision for the procurement was to focus on people and not just the business of managed care. This is the first structural change to Ohio’s managed care system since the Centers for Medicare & Medicaid Services' (CMS) approval of Ohio’s Medicaid program in 2005. Initially, all of the new managed care programs were supposed to be implemented starting on July 1, 2022. However, ODM Director Maureen Corcoran recently confirmed that this date will be pushed back for several managed care-related programs.

Laboratory Specimen Collection Arrangements with Contract Hospitals - OIG Advisory Opinion 22-09

On April 28, 2022, the Department of Health and Human Services, Office of Inspector General (“OIG”) published an Advisory Opinion[1] in which it evaluated a proposed arrangement where a network of clinical laboratories (the “Requestor”) would compensate hospitals (each a “Contract Hospital”) for specimen collection, processing, and handling services (“Collection Services”) for laboratory tests furnished by the Requestor (the “Proposed Arrangement”). The OIG concluded that the Proposed Arrangement would generate prohibited remuneration under the federal Anti-Kickback Statute (“AKS”) if the requisite intent were present. This is due to both the possibility that the proposed per-patient-encounter fee would be used to induce or reward referrals to Requestor and the associated risk of improperly steering patients to Requestor.

Property Owner Protection from Tax Valuation Challenges

New legislation provides significant new protections for commercial property owners against challenges to valuation primarily by local school boards and prohibiting side agreements to avoid tax valuation changes. The Ohio Legislature has approved House Bill 126 which will go into effect July 2022 but will effectively apply to the 2023 tax valuation year.