The Evolution of Foreign Account Tax Reporting

The IRS and Treasury face a number of challenges in administering our tax and financial systems. This includes challenges presented by foreign transactions by U.S. citizens and residents. In recent years, high-profile cases involving Americans using offshore accounts to evade taxes have prompted the U.S. government to crack down on tax evasion and make it……

Taxpayer Loses for Tax Court Petition Filed 11 Seconds Late

The voluntary nature of income tax returns in the United States means that taxpayers are responsible for reporting their income and paying the appropriate taxes. Taxpayers do this largely as it is the right thing to do. This is premised on a perception that the tax system has some elements of being fair and uniform……

Recovering Legal Expenses for Mistaken IRS Audit of Non-Resident

The U.S. has significant and complex reporting and filing and notice requirements. This includes a myriad of state and local requirements and federal requirements, including income tax return filing requirements. As odd as it sounds, it is part of what makes America great. We often don’t think about it, but these filing requirements are part……

The Disguised Dividend for Owner-Employees

The corporation can be viewed from a number of different perspectives. One way is to view it as a group of people coming together to perform some business activity, with each having different relationships and risks in the arrangement. The role any one individual plays in the corporation may not be clearly defined. The owner-employee……

Gift Tax Return for Wrong Year Starts IRS Statute of Limitations

The IRS receives a vast amount of information, which can make it challenging for them to act on all the information they possess. However, taxpayers have the ability to alert the IRS to potential tax issues and wait for the IRS’s response. The IRS generally cannot ignore information it has received. For example, in the……

The Collection Exception to Notice for IRS Summons

In tax disputes, the IRS holds a considerable advantage, as the law is often stacked in their favor, granting them broad collection powers. When all other avenues fail, the IRS summons becomes their primary tool for obtaining taxpayer records and information needed to assess and collect taxes. Despite the summons rules being unchanged for a……

Calculate Tax Loss for Criminal Tax Cases: Why It Matters

In the realm of criminal tax cases, time is of the essence. The criminal process operates at a markedly faster pace than the civil tax assessment process, creating a situation where defendants often overlook the precise amount of the tax loss they are accused of. While the tax-related details, including the actual amount owed, may……

Tax on Funds Received as an Intermediary Conduit

As tax attorneys in Houston, we often see investments made by local ethnic communities that are focused on investing overseas or raising money from overseas. This often involves those who immigrate to the U.S. from foreign countries, and do well in the U.S. financially. The investments are often made based on direct knowledge of opportunities……

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