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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…
Category: Tax
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……
Liability for Prior Real Estate Owner’s Unpaid IRS Taxes
Liability for Prior Real Estate Owner’s Unpaid IRS Taxes You have to be diligent if you buy real estate from someone who owes unpaid taxes to the IRS. There are instances where the IRS can collect the prior owner’s taxes from you as the purchaser of the property. The recent Shirehampton Drive Trust v. JP…Continue…
The Affirmative Act of Tax Evasion
Taxpayers get behind on their taxes as they do every other type of liability. It happens. But owing the IRS unpaid taxes can be more than a civil problem. Non-payment can lead to criminal tax evasion charges. The United States v. Connerton, No. 3:17-cr-47 (D. Conn. 2019), case provides an opportunity to consider the “affirmative……
The Broad Reach of the Economic Substance Doctrine
Congress provides tax incentives to change taxpayer behavior. If a taxpayer changes their behavior to take advantage of the incentive, they have to do so carefully. The IRS and the courts can apply the economic substance doctrine to take away… Read More The post The Broad Reach of the Economic Substance Doctrine appeared first on Houston…