Potential Opportunity For Certain Taxpayers To Avoid Certain International Compliance Penalties For The 2019 And 2020 Tax Years

August 24, 2022

The IRS recently issued Notice 2022-36, which provides a potential opportunity for penalty relief to certain people and businesses who file certain 2019 and 2020 tax and information returns late.

The relief applies to the failure to file penalty which is typically assessed at a rate of 5% per month and up to 25% of the unpaid tax when a federal income tax return is filed late. This relief applies to forms in both the Form 1040 and 1120 series, as well as others listed in Notice 2022 – 36 also provides details on relief for filers of various international information returns, such as those reporting transactions with foreign trusts, receipt of foreign gifts, and ownership interests in foreign corporations.

To qualify for this relief, any eligible income tax return must be filed on or before Sept. 30, 2022.

For more information, please contact Leslie A. Share, Jose Nuñez, Todd Rosenberg, Alfredo Tamayo, Barrie Erasmous or Flor Morillo.