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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.

El Contrato Escrito: La Herramienta Predilecta

No existe mejor herramienta a una disputa contractual que un documento firmado por las partes en el cual se expongan las obligaciones y acuerdos entre éstas.

New State Budget Institutes Licensure Requirement for Ohio’s Hospitals

On July 1, 2021, Governor Mike DeWine signed Ohio’s final budget codified at Ohio Revised Code 3722.01 et seq., which includes a new licensing requirement for Ohio’s hospitals. For years, Ohio was the only state in the country that did not license its hospitals. This approach will now be replaced with new, detailed requirements that will require careful review and compliance. Here are some of the highlights concerning these new changes:

Healthcare Provisions in the Ohio FY 22-23 Budget

Governor Mike DeWine signed Ohio’s Fiscal Year 2022-2023 budget bill (HB 110) into law on July 1, 2021. At almost 1,000 pages and 74.1 billion dollars, the budget lays out the State’s spending for the next two years. Below are a few highlighted provisions from the budget that will be important for the healthcare industry in Ohio

Interim Final Rule for Surprise Billing

In an effort to implement the new bipartisan No Surprises Act, on July 1, 2021, the Department of Health and Human Services (HHS), along with the Departments of Labor and Treasury, issued an interim final rule to safeguard patients against unforeseen medical bills arising from out-of-network care.

President Biden Seeks to Limit Non-Compete Agreements

Today, President Biden announced he would issue an Executive Order that calls on the Federal Trade Commission (FTC) to adopt rules to curtail worker non-compete agreements. Interestingly, a week ago, the FTC approved changes to its Rules of Practice to modernize and expedite the way it issues Trade Regulation Rules. If you have followed our alerts, we predicted the elimination of non-competes would probably happen. In 2016, then-Vice President Biden was a vocal opponent against non-compete agreements. He led the Obama administration’s initiative seeking to limit or eliminate non-compete agreements. In his presidential campaign, Biden promised to “work with Congress to eliminate all non-compete agreements, except the very few that are absolutely necessary to protect a narrowly defined category of trade secrets . . ..”