PBF Global Advisors

The IRS may owe you.

A recent court decision opened a refund-and-abatement window on COVID-era penalties — but it closes soon



⏳ Deadline to file — July 10, 2026

We're flagging a recovery opportunity that could mean real money back for you.

Kwong v. United States, 179 Fed. Cl. 382 (Nov. 2025)

The decision raises serious questions about whether certain IRS penalties and related interest were properly assessed during the COVID-19 federal disaster period. Under IRC §7508A, the IRS postponed numerous deadlines between January 20, 2020 and July 10, 2023 — and the Kwong court held that some penalties assessed in that window may have been improperly imposed.

120M+ penalties assessed during that period, per the Taxpayer Advocate Service — many of which may now be challengeable.

This is not automatic relief. The IRS will not fix these accounts on its own. To preserve a your rights, you generally must affirmatively file a protective claim before the deadline. Depending on the client's situation:

▸ Penalties already paid → potential refund opportunity.
▸ Penalties still outstanding → potential abatement opportunity.
▸ Clients with Failure-to-File, Failure-to-Pay, or Estimated Tax penalties (and related interest) during the disaster period are worth reviewing first.

The deadline is firm: July 10, 2026. After that date, the National Taxpayer Advocate has warned that many taxpayers may permanently lose the right to pursue these claims.

The IRS may owe you. A recent court decision opened a refund-and-abatement window on COVID-era penalties — but it closes soon Click here for an update from PBF Global, LLC!

Quarterly Estimated Tax Payments Are Due Today

Dear PBF Global Clients,

This is a reminder that quarterly estimated tax payments are due today, June 15, 2026, for taxpayers who are required to make estimated payments toward their 2026 federal income tax liability.

Estimated tax payments generally apply to taxpayers who have income that is not fully covered by withholding, including business income, self-employment income, investment income, rental income, retirement income, and other sources of taxable income.

Why These Payments Matter

The IRS requires taxpayers to pay income taxes throughout the year as income is earned. Failure to make required estimated payments may result in penalties and interest.

For clients who are seeking or may later seek tax resolution, including an Offer in Compromise, installment agreement, or other IRS collection alternative, staying current is especially important. The IRS generally requires taxpayers to be in compliance, which includes filing required returns and making required estimated tax payments, before it will consider an Offer in Compromise. Continuing compliance also helps protect any resolution strategy already in progress.

How to Make Your Estimated Tax Payment

You may make your federal estimated tax payment using one of the following IRS payment methods:

1. IRS Direct Pay

Individuals may pay directly from a checking or savings account using IRS Direct Pay. This is generally the simplest method for individual taxpayers.

When making the payment, select:

Reason for Payment: Estimated Tax
Apply Payment To: 1040ES
Tax Period for Payment: 2026

2. IRS Online Account

Taxpayers may also make payments through their IRS Online Account, where they can view payment history and certain tax records.

3. EFTPS

Businesses and individuals may use the Electronic Federal Tax Payment System, commonly referred to as EFTPS. This is often used for business payments and scheduled recurring payments.

4. Debit Card, Credit Card, or Digital Wallet

The IRS also permits payment by debit card, credit card, or digital wallet through approved processors. Please note that processing fees may apply.

5. Payment by Mail

Taxpayers may also mail a check or money order with the appropriate estimated tax voucher, such as Form 1040-ES. If mailing, please make sure the payment is postmarked timely and that your Social Security number or EIN, tax year, and payment type are clearly referenced.

State Estimated Tax Payments

Please remember that federal estimated tax payments do not automatically cover state obligations. If you are required to make state estimated tax payments, those payments must be made separately through your state’s tax agency.

Important Note for Tax Resolution Clients

If PBF Global is assisting you with IRS tax resolution, collections, an Offer in Compromise, or a payment arrangement, please notify us once your estimated tax payment has been made. Timely estimated tax payments help demonstrate current compliance and strengthen your overall resolution position.

If you are unsure whether you are required to make an estimated tax payment or need assistance determining the proper amount, please contact PBF Global as soon as possible.

Sincerely,

PBF Global, LLC

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Extension For Individual Income Tax Request

In an effort to insure that all clients and relationships are covered for the April 15th Deadline, we are kindly asking that you procure your extension today. Thank you.

Request for Individual Income Tax Extension from PBF Global, LLC Click here for an update from PBF Global, LLC!

Leveraging a Defined Benefit Plan with Life Insurance for Maximum Tax Advantages

In the world of retirement planning, combining a defined benefit plan with life insurance can unlock powerful tax advantages while ensuring financial security for both business owners and key employees. This strategic approach not only allows for substantial tax deductions but also creates a tax-efficient means of accumulating wealth and providing financial protection for loved ones.

How a Defined Benefit Plan with Life Insurance Works

How a Defined Benefit Plan with Life Insurance Works
A defined benefit plan is a type of employer-sponsored retirement plan that promises a specified benefit at retirement, based on factors like salary history and length of service. When life insurance is incorporated into a defined benefit plan, it adds a layer of financial security and tax efficiency.

Key Benefits

✅ 100% Tax-Deductible Contributions
Contributions to a defined benefit plan are fully tax-deductible for the employer, which reduces the company's taxable income. This allows businesses to fund future pension obligations for key employees while simultaneously reducing current tax liability.

✅ Tax-Deferred Growth
When life insurance is included within the defined benefit plan, the policy's cash value grows and compounds tax-free. This allows the accumulated value to grow faster than it would in a taxable account, enhancing the long-term retirement benefit.

✅ Tax-Free Death Benefit
If the life insurance policy names family members as beneficiaries, the death benefit is generally paid out tax-free to them, providing additional financial protection without increasing the tax burden.

A Practical Example

Consider a business owner facing a $100,000 tax liability at a 40% tax rate. By contributing $250,000 to a defined benefit plan that includes life insurance, the entire contribution would be fully tax-deductible. This would:

Effectively eliminate the $100,000 tax liability ($250,000 x 40% = $100,000).

Build retirement assets through the growth of the cash value within the plan.

Ensure that any death benefit paid out to family members remains tax-free.

This strategy not only lowers current tax obligations but also strengthens the business owner’s retirement position and provides financial security for their family.

Strategic Flexibility and Future Planning

Using a defined benefit plan with life insurance offers significant tax advantages and flexibility in funding retirement. However, continued tax planning is essential to optimize long-term benefits. Structuring the plan properly and monitoring changes in tax laws will ensure that both the business and the key employees maximize the available advantages.

This strategy creates a win-win scenario: reducing current taxes, funding retirement, and providing financial protection for your loved ones—all while building a more secure financial future.

Leveraging a Defined Benefit Plan with Life Insurance for Maximum Tax Advantages Click here for an update from PBF Global, LLC!