Tag: Houston Tax Attorney

Payroll tax disputes can be more difficult to resolve with the IRS than some other types of taxes. This is largely due to the IRS’s notice of deficiency process. The IRS’s notice of deficiency is the final notice the IRS sends before it assesses or records a tax as being due. The notice is required…Continue…

The process for reporting taxes can be more difficult than discerning whether a tax provision applies. This complexity stems from the level of information is required to be reported. The IRS reporting requirements continue increase every year. The IRS’s decision to require partnership tax capital accounts is an example. Why is that information required and…Continue…

There are ways to structure transactions to avoid income taxes. Creative taxpayers and tax attorneys have used qualified retirement accounts for this purpose (the tax savings from ESOPs is an example). One has to be careful when structuring transactions involving these qualified plans. Given the flexibility in the rules and the absence of financial advisors,…Continue…

Just about every business starts out with losses. This is the nature of start-ups. The activity will either gain traction and produce income and possibly a profit or, eventually, the activity end. This is basic economics and capitalism at work. The U.S. economy is based on these concepts, allowing would-be entrepreneurs the opportunity and motive…Continue…

The IRS refocused its efforts on international tax issues about ten years ago. This effort has yielded scores of transfer pricing, foreign tax credit, and similar tax disputes. While not as prominent as transfer pricing and foreign tax credit disputes, the IRS has also focused on U.S.-sourced income that is not reported. The IRS has…Continue…

Taxpayers have several choices to make when starting a business. One of these choices is how to fund the business. They can fund the business with capital contributions or debt (or a combination thereof). The IRS and courts will usually follow the method the taxpayer uses. Many taxpayers do not consciously decide this issue. They……

Taxpayers have several choices to make when starting a business. One of these choices is how to fund the business. They can fund the business with capital contributions or debt (or a combination thereof). The IRS and courts will usually follow the method the taxpayer uses. Many taxpayers do not consciously decide this issue. They…Continue…

The contract for deed can provide a way to transfer ownership of property to someone who owes back taxes to the IRS, while preserving the right to avoid the IRS lien and IRS foreclosure. Real estate investors and those doing real estate deals may prefer these sales as they can often be made at higher…Continue…

The IRS sends out a lot of letters. It usually uses the U.S. Postal Service to send these letters. The volume of letters is so high that the IRS may be the U.S. Postal Service’s largest customer. These IRS letters are often required. These requirements are found in the Code. The requirement that the IRS…Continue…

What happens if you make a technical foot fault while working with the IRS? Say you miss a deadline or a filing requirement. Can the IRS waive compliance with the deadline or requirement? IRS personnel will often say that they cannot. But in reality, the IRS can waive most procedural requirements. The authority for this…Continue…