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If a company acquires another company and pays a finders fee to the party who connected the two for the sale, is the finders fee deductible by the acquirer? This question touches on whether an expense is deductible if the… Read More The post M&A Finders Fee Not Deductible for Acquirer appeared first on Houston Tax…
Category: Tax
The IRS Summons & When the IRS Fails to Follow the Law
What happens if the law requires the IRS to provide notice to the taxpayer and the taxpayer to provide notice to the IRS and both parties fail to provide the notice? Can the government ignore its failure and enforce consequences for the taxpayer’s failure? The answer is “yes” when it comes to the IRS summons,…Continue…
Using Multiple PTINs to File Fraudulent Tax Returns
It can be difficult to be a tax preparer. The rules change just about every year. The IRS has increased its focus on identifying and punishing tax return preparers. This includes criminal sanctions for the tax return preparers. The enforcement actions often do not factor in the realities of the tax preparation business. The recent……
Qualifying for the Foreign Earned Income Exclusion
As tax attorneys in San Antonio, we see a lot of U.S. citizens whose oil-related jobs require they spend significant time overseas. The wages earned overseas can escape tax in the U.S. This is due to the foreign earned income exclusion. But this exclusion generates quite a few tax disputes with the IRS, which is…Continue…
Can the IRS Collect Gift Tax From Recipient After 14 Years?
If someone gives you property and then dies and more than ten years has passed since the gift, can the IRS sue you to collect the amount of the gift from you? Most would think the answer is a resounding… Read More The post Can the IRS Collect Gift Tax From Recipient After 14 Years? appeared…
Avoiding State Income Tax on Part-Time Residents
Sometimes you can’t avoid paying state income taxes. This is true for those who have no ties to any state other than a state that has an income tax. But for those who have ties to multiple states, they can… Read More The post Avoiding State Income Tax on Part-Time Residents appeared first on Houston Tax…
S Corp Conversions: Watch out for Disappearing AAA
Small and medium-sized business can save quite a bit in taxes by using S corporations. But with this tax savings comes complexity. This complexity comes from how S corporations flow through profit and have the profit taxed on the individual… Read More The post S Corp Conversions: Watch out for Disappearing AAA appeared first on Houston…
Does Late Payment Tax Penalty Run from Extended Due Date?
If you file an extension for an estate tax return and pay the tax before the extended due date, can the IRS impose penalties for late payment? The court addresses this in Estate of Agnes R. Skeba v. United States, No. 3:17-cv-10231 (D.N.J. 2019). Facts & Procedural History The taxpayer is an estate. It’s estate……
Final Regulations Issued: Leveraged Partnership Distributions Still Viable
The “leveraged partnership distribution” or “disguised sale” is a common tax savings technique used by real estate owners. Taxpayers pushed the envelope with these transactions by using “bottom dollar guarantees.” This led to guidance from the government making it more… Read More The post Final Regulations Issued: Leveraged Partnership Distributions Still Viable appeared first on Houston…
Discharging Unpaid Withholding Taxes in Bankruptcy
When a business owes unpaid taxes, bankruptcy can provide the business or its owner with a fresh start. The unpaid Federal taxes can be discharged if certain requirements are met. One of these requirements is that the tax returns for the unpaid taxes are filed within certain time periods. But what if there are more……