Client Alerts, News Articles & Blog Posts

Everything you need to know about BMD and the industry.

IRS Grants Additional Extensions and Suspends Collection Activity

More Extensions Granted for Filing Returns

In addition to those previously announced, the IRS has granted extensions for filing of the following returns and payments of amounts due for any of the returns listed below due after April 1, 2020 and before July 15, 2020:

  • Form 706 - Estate and Generation-Skipping Transfer Tax;
  • Form 8971 – Information Regarding Beneficiaries Acquiring Property form a Decedent;
  • Form 709 – United States Gift (and Generation-Skipping Transfer) Tax;
  • Any Estate Tax payment due as a result of an election under sections 6166, 6161, and 6163;
  • Form 990-T – Exempt Organization Business Income Tax;
  • Form 990-PF – Return of Private Foundation or Section 4947 Trust;
  • Form 4720 – Return of Certain Excise Taxes; and
  • All estimated payments made on Form 990-W; 1040-ES, 1041-ES, 1120-W.

(This is a change from the extension of only the first quarter estimate to include the June 15, 2020, estimate).

Collection Actions

The IRS is suspending most collection actions between April 1, 2020 and July 15, 2020.  The specific actions are outlined below:

  • Installment Agreements
    • Those which are currently in place will have all payments suspended between April 1 and July 15. However, if you are paying by automatic debit, you must contact your bank to suspend the payment.  If you do so, please remember to contact your bank to have payments resume in July.
    • New installment agreements may be submitted on the IRS website for those eligible to automatically be qualified for an installment arrangement. All others will not currently be processed.
  • Offers in Compromise
    • Those with pending OICs will have until July 15 to provide any requested information. No request will be closed before July 15 unless the taxpayer has requested the closure;
    • All payments under current OICs may suspend payments until July 15. Be advised that interest continues to accrue during this period;
    • Any current OIC will not be defaulted for failure to file their 2018 return provided they file the return on or before July 15; and
    • New OIC applications may be filed but will not be worked. As a practical matter, these applications should not be prepared or submitted until closer to the July 15 date in order to avoid having to provide updated information.
  • Liens, Levies, and Passport Certifications
    • Automated liens and levies will be suspended during this period;
    • Liens and Levies initiated by field revenue officers will be suspended;
    • High income non-filers will continue to have collection actions during this period; and
    • New certifications to the Department of State for passport holds will be suspended during the period.
  • Private Debt Collection has not been suspended. However, from a practical standpoint there may not be much if any activity from private debt collectors.
  • Audits and Appeals
    • All in-person meetings have been suspended, but examiners will continue to work on matters remotely. Taxpayers are encouraged to respond to any correspondence they receive if they are able.
    • New audits (including correspondence audits) will not be started UNLESS the IRS deems it necessary to protect the government’s interest.
    • Appeals officers will continue to work cases. Conferences will be held by telephone or videoconference.

For questions, or more information, please contact BMD Tax Member, Priscilla Grant at pag@bmdllc.com or 330.253.5934.

Changes to Physician Assistant Statutes in Florida

In the last year, there have been many changes to the scope of practice and collaboration/supervision requirements for advanced practice providers such as APRNs and physician assistants in the state of Florida. In a previous Client Alert we discussed House Bill 607, which expanded the autonomous practice of APRNs providing primary care services in Florida.

Ohio Senate Bill 49 – Ohio Expands Lien Rights for Design Professionals

Effective September 30, 2021, Ohio granted limited lien rights to design professionals, including architects, landscape architects, engineers, and surveyors. Ohio Governor Mike DeWine signed Senate Bill 49 into law on July 1, 2021. This new law established a statutory right to lien commercial real estate by Ohio design professionals who, until now, could not file a lien for non-payment of professional services. Senator Vernon Sykes, a primary sponsor of Senate Bill 49, stated that the “legislation ensures that architects, engineers and other designers will get paid for their work, regardless of the outcome of their projects . . . It will support hardworking Ohioans by protecting the value of their labor . . ..”

Primary Care Practice Officially Defined in Florida for APRNs Practicing Autonomously

As many providers in Florida are aware, House Bill 607 (the “Bill”), which was passed in February of last year, gives certain APRNs in Florida the ability to practice autonomously. The only catch is that they must work in primary practice. When the Bill was initially passed, there was question as to what was exactly considered primary care, absent a definition from the Florida Board of Nursing. However, as of February 25, 2021, “primary care practice” has officially been defined.

Part II of the No Surprises Act

The Department of Health and Human Services (“HHS”) published Part II of the No Surprises Act on September 30, 2021, which will take effect on January 1, 2022. The new guidance, in large part, focuses on the independent dispute resolution process that was briefly mentioned in Part I of the Act. In addition, there is now guidance on good faith estimate requirements, the patient-provider dispute resolution processes, and added external review provisions.

Safer Federal Workforce Task Force - Guidance for Federal Contractors and Subcontractors

The Safer Federal Workforce Task Force has issued its Guidance for Federal Contractors and Subcontractors (Guidance). Note that the Guidance applies only to “covered contracts,” which are contracts that include the clause (Clause) set forth in Sec. 2(a) of Executive Order 14042 (Ensuring Adequate COVID Safety Protocols for Federal Contractors). The Federal Acquisition Regulatory Council (FARC) is to conduct rulemaking and take related action to ensure that the Clause is incorporated into federal contracts. Until that happens, federal contractors likely will not see the Clause in its contracts. Following is a broad summary of the Guidance.