If a Foreign Entity is a Foreign Trust

United States persons who have foreign transactions present a number of compliance problems for the IRS. It is difficult for the IRS to know whether taxpayers are simply not paying U.S. taxes on foreign transactions. The IRS officially recognized the significance of its international tax limitations in 2010 when it renamed its large business division……

Can a Tax Attorney Sign a Form 843?

Taxpayers may find it challenging to obtain a refund from the government, as the courts and Congress have imposed stringent requirements on the refund claims filed by taxpayers. Even minor procedural errors can be detrimental to the claim, resulting in the government gaining an unwarranted windfall. The recent case of Vensure HR, Inc. v. United……

Amount of 179D Tax Deduction for Building Designer

Congress often creates tax incentives, but it is up to the IRS and courts to determine their implementation and interpretation. The Sec. 179D tax deduction is an example of this. The statute provides broad concepts but lacks substance, leading to the courts playing a crucial role in determining its implementation and interpretation. The details matter……

The Premium Tax Credit Trap

In an effort to reform health insurance, the government implemented a system where it would make payments directly to insurance companies on behalf of taxpayers through the use of premium tax credits. These credits were a part of the Affordable Care Act and intended to make health insurance more affordable for those who might not……

The Crime-Fraud Exception to the Attorney-Client Privilege

Our laws protect certain communications. This includes communications with doctors, religious advisors, spouses, and even attorneys. When it comes to Federal tax matters, communications with tax attorneys are usually at the forefront. The IRS often seeks information about these communications to help it figure out how the taxpayer structured their affairs. The attorney-client privilege is……

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