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……

S Corporation: Distribution of Appreciated Assets

Those who set up S corporations usually do so as their accountant told them that it could save taxes. This is often true. The S corporation can result in tax savings. This may include the standard reduction in self-employment/payroll taxes or, for more advanced tax planning, income taxes. The ability to freeze the value of……

Pay IRS Estimated Tax Prior to Filing Bankruptcy

Taxes incurred just prior to filing bankruptcy are not dischargeable in bankruptcy. The debtor will have to pay these taxes or work out a collection alternative with the IRS for these taxes. This raises the question as to whether a debtor can basically pay the IRS estimated payments to satisfy their income taxes for the……

Court Says IRS Issuing Six Summonses is Not Bad Faith

The IRS has a lot of power. This power stems from the broad Congressional grant of authority to examine books and records to enforce our tax laws. Since taxes impact every individual and business for every transaction (and even inactions), this allows the IRS to audit and inquire into just about anything it wants to.……

Can a Forensic Accountant Testify as an Expert?

One of the most frequent disputes in IRS audits is whether the taxpayer had unreported income. This is income that the taxpayer failed to report on his or her income tax return. This typically involves cash a business or service provider received from clients. It may also include non-cash deposits into financial accounts. This “income……

The Qualified Nonpersonal Use Vehicle

What Congress provides with one provision, it often takes away with another. This can result in legal challenges whereby the court creates exceptions. The exceptions can be modified and qualified by later legislation. This creates a labyrinth that one has to navigate to determine how an item is treated for federal income tax purposes. The……

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