June 29, 2020
June 22, 2020
- PPP Loan Forgiveness Application Forms Updated and Streamlined
- Nevada Division of Insurance to Disallow Policy Exclusions Related to COVID-19
- CDI Announces New Order Regarding Workers’ Compensation Premium Savings for CA Businesses Affected by COVID-19
june 15, 2020
june 10, 2020
- Note to the SBA: Debtors in Bankruptcy Are Eligible for PPP Loans
- California Modifies the Tolling of Statutes of Limitations in Civil Cases
june 8, 2020
- CCPA Enforcement Date Fast Approaching Regardless of COVID-19
- Hotels in California May Be Days Away From Reopening: What Hoteliers Need to Know
June 4, 2020
may 29, 2020
may 28, 2020
- House Introduces Pandemic Risk Insurance Act of 2020 in the Wake of COVID-19 Business Interruption Claims
may 27, 2020
- Hoteliers Beware: a Return to Business Post-Pandemic Brings With It Potential Legal Liability
- House Contemplates Revisions to the Paycheck Protection Program
may 15, 2020
may 14, 2020
- U.S. House Democrats Introduce HEROES Act, a New $3T Stimulus Package
- SAFE Banking Act for Cannabis-Related Businesses Included in the HEROES Act
may 12, 2020
may 8, 2020
- Treasury and the SBA Issue Guidance Regarding the Employee Retention Credit
- Businesses Reopen in Los Angeles County as Stage 2 of California’s Statewide Plan Begins
- Update: Large Employers Required to Pay Coronavirus-Related Sick Leave Under New L.A. County Ordinance
may 6, 2020
- SBA Extends PPP Certification Safe Harbor to May 14
- A 2008 Redux: IRS Provides Temporary Cash/Stock Dividend Relief for Publicly Offered REITs and RICs
- EPLI Insurance and Employee Benefits in the Age of the Coronavirus
may 5, 2020
- Update: PPP Guidance Issued by the SBA and U.S. Treasury at Odds With the CARES Act—Michelman & Robinson Files First-of-Its-Kind Lawsuit Challenging FAQs
- NAIC Issues Business Interruption Data Call in the Wake of COVID-19
may 4, 2020
- PPP Guidance Issued by the SBA and U.S. Treasury at Odds With the CARES Act—Michelman & Robinson Files First-of-Its-Kind Lawsuit Challenging FAQs
may 1, 2020
april 29, 2020
- Planning for Your Employees' Return to the Workplace
- Los Angeles Hospitality Workers Among Those Thrown a Potential Lifeline
april 24, 2020
- Attention Cannabis Businesses: Hope May Be on the Horizon for Federal COVID-19-Related Relief
- California Department of Insurance Issues Notice Granting Tax-Filing Extension in Response to COVID-19
- SEC Approves Amendments to Nasdaq and NYSE Continued Listing Requirements Due to the COVID-19 Pandemic
April 23, 2020
april 21, 2020
- Additional Funding Is on the Way to Resurrect the PPP
- Certifying Your PPP Loan: Proceed With Caution
april 17, 2020
april 16, 2020
- Employment in the Wake of Coronavirus: EEOC and OSHA Guidance Allows Employers to Go Where They Could Not Go Before
- New Yorkers Ordered to Stay at Home Even Longer Amid the COVID-19 Crisis
- Paycheck Protection Program Funds Exhausted
april 15, 2020
- Attention Insurers: the CDI Has Ordered You to Fairly Investigate All Business Interruption Insurance Claims Caused By the COVID-19 Outbreak
April 14, 2020
- Insurance Companies Have Been Ordered to Provide COVID-19-Related Premium Relief to Businesses and Drivers in California
- What to Do If Your New York Business Has Been Deemed Non-Essential
APRIL 13, 2020
- IP Deadlines and Fees Extended Under the CARES Act
- Employment in the Wake of Coronavirus: Reintegrating Your Workforce in the New Normal
APRIL 10, 2020
- You Successfully Applied for and Received a PPP Loan Under the CARES Act: Now What?
- Safer at Home Order in L.A. Extended to May 15
- Maintaining Your Trade Secrets During the Coronavirus Crisis
APRIL 9, 2020
april 8, 2020
- Congress Looks to Bolster the PPP With Another $250B in Funding
- U.S. Treasury Provides Further Guidance to PPP Borrowers and Lenders
- L.A. Mayor Amends COVID-19-Related Paid Sick Leave Ordinance
april 7, 2020
- Clarifying the Paycheck Protection Program: Payment of Insurance Premiums and Loan Forgiveness under the CARES Act
April 3, 2020
april 2, 2020
april 1, 2020
March 31, 2020
march 30, 2020
- Large Employers Required to Pay Coronavirus-Related Sick Leave Under New L.A. Ordinance
- Insurance Coverage Potentially Triggered by COVID-19
- Attention Insurers: CDI Orders Mandatory Call for Business Interruption Coverage Information in the Wake of COVID-19
- DOL Is Requiring Employers to Post Families First Employee Rights Notice
March 27, 2020
- A Comprehensive Guide to Understanding Coronavirus-Related State Assistance Programs: Who is Giving What to Whom (Part II)
- IRS Releases “People First Initiative” Temporarily Adjusting and Suspending Key Compliance Actions
- HHS Relaxing Enforcement of HIPAA to Facilitate Sharing of Information During the COVID-19 Crisis
March 26, 2020
march 25, 2020
march 24, 2020
- Navigating the Coronavirus Pandemic: a Critical Business Review Checklist
- SBA Loans for Companies Impacted by Coronavirus
- SEC Relaxes Federal Proxy Rules for Annual Meetings
march 23, 2020
- Federal Reserve Responds Boldly to Coronavirus-Related Economic Downturn
- The Number of Jurisdictions Implementing Stay-at-Home Orders Is Increasing Exponentially
- Michelman & Robinson’s Guide to Coronavirus-Related Paid Sick Leave and Unemployment Insurance Laws in the Tri-State Area
MARCH 21, 2020
- New Jersey Orders Its Residents to Stay Home
- “Essential Businesses”— What if I am Stopped?
- The IRS and States Provide Tax Relief in the Wake of the Coronavirus Pandemic
MARCH 20, 2020
- New York Governor’s PAUSE Order
- Illinois Governor’s Statewide Stay-at-Home Order
- Force Majeure Clauses in Commercial Real Estate Contracts
MARCH 19, 2020
- SEC Provides Regulatory Relief for Public Reporting Companies
- Student Loan Borrowers Can Breathe a Sigh of Relief, At Least Temporarily
- California Governor's Statewide Stay-At-Home Order
MARCH 18, 2020
- "Shelter in Place" Orders
- Telecommuting in the Age of Coronavirus
- Families First Coronavirus Response Act Just Passed by the Senate and Signed Into Law by the President
MARCH 17, 2020
- M&R Coronavirus Risk Mitigation Team: A Multi-Disciplinary Legal Team Ready To Immediately Address A Host Of Coronavirus-Related Issues for Businesses, Quickly And Holistically
MARCH 16, 2020
MARCH 5, 2020
IRS Releases “People First Initiative” Temporarily Adjusting and Suspending Key Compliance Actions
The Internal Revenue Service continues to respond in the wake of the COVID-19 pandemic. On the heels of the decision to move tax day to July 15—as Michelman & Robinson reported here—the agency has taken additional measures to relieve taxpayer burdens.
In News Release IR-2020-59, the IRS announced its “People First Initiative” that, among other things, eases certain payment guidelines and postpones compliance actions. M&R provides the details here in question and answer form.
Q. When will the “People First Initiative” come online?
A. The IRS has targeted April 1 as the start date of the program, with the initiative running—at least initially—through July 15.
Q. What is the IRS doing for taxpayers currently making installment payments?
A. Payments due between April 1 and July 15 under existing installment agreements are being suspended. In addition, under the “People First Initiative,” the IRS will not find taxpayers in default of any installment agreements during this period. That being said, interest will continue to accrue on any unpaid balances.
Of note, taxpayers unable to pay their federal taxes in full may continue to enter into monthly payment agreements with the IRS, consistent with historic practice.
Q. Are offers in compromise (OIC) impacted by the “People First Initiative”?
A. Yes, the IRS has made its own compromises relative to OICs as follows:
- Pending OIC Applications – The time period to provide requested additional information to support a pending OIC has been extended to July 15, and the IRS will not close any pending OIC request before then without the taxpayer’s consent
- OIC Payments – Taxpayers may suspend all payments on accepted OICs until July 15 (interest will continue to accrue on any unpaid balances)
- Delinquent Return Filings – The IRS will not default an OIC for taxpayers who are delinquent in filing their 2018 tax return; however, the IRS encourages taxpayers to file any delinquent 2018 return, in addition to their 2019 returns, on or before July 15
- New OIC Applications – The OIC process is designed to resolve outstanding tax liabilities by providing a “Fresh Start” for those facing a tax liability exceeding their net worth
- Non-Filers – Taxpayers who have not filed their tax returns for the years prior to 2019 should do so and should also consider entering into an installment agreement or OIC to the extent necessary (and especially if they are “seriously delinquent”)–procedures historically designed to prevent delinquent taxpayers from receiving or renewing passports will also be temporarily suspended
Q. Will field collection activities be scaled back for a time?
A. Yes, while IRS field revenue officers will continue pursuing high-income non-filers when they deem appropriate, they will be suspending liens and levies—including seizures of personal residences—until at least July 15. At the same time, the IRS will suspend new automatic, systemic liens and levies until at least July 15 as well.
Q. Does the “People First Initiative” impact private debt collection?
A. Yes, the IRS will not forward new delinquent accounts to private collection agencies.
Q. Has the IRS changed its position on field, office, and correspondence audits?
A. It has. Generally, the IRS will not begin new field, office, and correspondence examinations; however, it will continue to work refund claims (where possible) and may start new examinations in the interest of protecting the government’s interest in preserving the applicable statute of limitations. More specifically:
- In-person meetings will be suspended, though IRS examiners will continue their examinations remotely where possible
- The IRS may initiate activities to move forward with an examination, where in the best interest of both parties, for certain corporate and business taxpayers while people and records are available for examination
- Taxpayers are encouraged to respond to IRS correspondence requesting additional information–this is particularly true with regard to outstanding requests for information for cases in the Independent Office of Appeals
- Regarding the Office of Appeals, it is not holding in-person conferences with taxpayers; however, it may proceed with these conferences remotely over the phone or by video-conference
Q. What about Earned Income Tax Credit and wage verification reviews?
A. Taxpayers now have until July 15 to respond to the IRS in order to verify that they qualify for the Earned Income Tax Credit and to verify income. The IRS will not deny these credits for failure to provide requested information, until at least July 15.
Q. Does the “People First Initiative" affect the statute of limitations?
A. The IRS will take steps necessary to protect the applicable statute of limitations, and it encourages taxpayers to cooperate in extending such a statute where expirations would otherwise occur during this time period.
Q. What can I expect from the Practitioner Priority Service (PPS)?
A. Depending on staffing levels and allocations, wait times for the PPS may be more significant than normal.
Q. Will the IRS be making any other coronavirus-related changes?
A. The IRS intends to review, modify and/or expand the "People First Initiative" as it receives feedback, and yes, it expects to issue additional guidance.
We are working diligently to keep our clients up to date on coronavirus-related developments. Nevertheless, these developments are changing daily and, in some cases even hourly, so it is important that you make sure you are dealing with the most current information. That being said, this alert is not offered, and should not be relied on, as legal advice. You should consult an attorney for guidance and counsel regarding any specific concern or situation.