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Last week, the IRS announced the People First Initiative, providing taxpayers with relief from several issues, such as postponing compliance deadlines and easing payment guidelines. The People First Initiative has an anticipated start date of April 1, 2020 and is scheduled to run through July 15, 2020. Some pivotal aspects of the People First Initiative are summarized below.

Installment Agreements

If you are a taxpayer with payments due under an existing Installment Agreement between April 1 and July 15, 2020, those payments are suspended. The IRS will also not default those Installment Agreements during that period. However, interest will continue to accrue on unpaid balances.

Offers in Compromise (“OIC”)

Taxpayers now have until July 15, 2020 to respond to IRS requests for additional information related to a pending OIC. The IRS will also not close any pending OIC requests before that date. Moreover, taxpayers now have the option to suspend all payments on accepted OICs until July 15 (interest will accrue on unpaid balances). The IRS will also not default an OIC for taxpayers delinquent in filing their 2018 tax return. Nevertheless, taxpayers should file 2018 and 2019 tax returns before July 15, 2020.

Liens and Levies

Liens and levies initiated by field revenue officers will be suspended during the April 1 to July 15, 2020 period. Likewise, new automatic, systemic liens and levies will also be suspended.

Audits/Examinations and Appeals

During the April 1 to July 15, 2020 period, the IRS will generally not start new field, office and correspondence examinations.  For current examinations, in-person meetings will be suspended and remote exams will be used where possible. IRS Appeals will continue to work cases, suspending in-person conferences and using remote conferencing where possible.

Conclusion

While the IRS is suspending many deadlines, taxpayers are encouraged to contact their tax professionals promptly to stay abreast of these developments. For instance, taxpayers must respond to the IRS by July 15, 2020 to verify that they qualify for the Earned Income Tax Credit or to verify their income. Be advised, that the IRS will continue to take action necessary to protect all applicable statutes of limitations. Additionally, high-income individuals who have not filed their tax returns for years prior to 2019 will continue to be pursued.  These individuals should consult with their tax professionals to jumpstart their tax compliance.

If you have any questions, please contact Gunster tax attorneys Lu-Ann Dominguez, (954) 468-1314, or Andrew Piper, (954) 712-1476.

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This publication is for general information only. It is not legal advice, and legal counsel should be contacted before any action is taken that might be influenced by this publication.

About Gunster

Gunster, Florida’s law firm for business, provides full-service legal counsel to leading organizations and individuals from its 12 offices statewide. Established in 1925, the firm has expanded, diversified and evolved, but always with a singular focus: Florida and its clients’ stake in it. A magnet for business-savvy attorneys who embrace collaboration for the greatest advantage of clients, Gunster’s growth has not been at the expense of personalized service but because of it. The firm serves clients from its offices in Boca Raton, Fort Lauderdale, Jacksonville, Miami, Orlando, Palm Beach, Stuart, Tallahassee, Tampa, The Florida Keys, Vero Beach, and its headquarters in West Palm Beach. With nearly 200 attorneys and 200 committed support staff, Gunster is ranked among the National Law Journal’s list of the 500 largest law firms and has been recognized as one of the Top 100 Diverse Law Firms by Law360. More information about its practice areas, offices and insider’s view newsletters is available at www.gunster.com.

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