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The tax assessment and collection process in most foreign countries is markedly different than the process in the U.S. These differences can present a number of challenges for U.S. citizens who reside in foreign countries. In Sotiropoulos v. Commissioner, T.C. Memo. 2017-75, the court considered one of these challenges, namely, how does one determine whether…
Category: Houston
Court Considers Economic Substance in S Corp Transactions
The IRS challenges some tax positions by asserting that the transactions lack economic substance. This can allow the government to unwind or ignore transactions that comply with our tax laws if there is no legitimate business purpose for the transactions other than tax savings. There is a growing body of court cases that helps define…
Eight Things You Need to Know About the IRS Offer in Compromise Program
An offer in compromise is a legal agreement between you and the IRS that settles your tax debt for less than the full amount you owe. It provides you with a path for paying off your tax debt and getting a “fresh start.” If you have unpaid tax debts, here are eight things you need…Continue…
Rules to Know When the IRS Seizes Your Property
The IRS has the authority to take your funds or property if you do not pay your taxes. This is commonly referred to as a “seizure.” Our Tax Code and the IRS’s Internal Revenue Manual provide specific rules and procedures the IRS has to follow to seize your property. Here are the four primary rules…Continue…
When the IRS’s Collection Efforts Create an Economic Hardship
The IRS has broad collection powers that it can bring to bear to collect unpaid taxes. Even though it has these powers, it often chooses not to use them. This is especially true in cases where the collection actions would result in an economic hardship for the taxpayer. What is an Economic Hardship? The term…Continue…
6 Tips for Avoiding the Trust Fund Recovery Penalty
If you are running a business and it is not withholding or remitting payroll taxes to the IRS, you should be aware of the trust fund recovery penalty. This penalty can make the business’ payroll taxes your personal tax problem. The IRS is able to assess the penalty against you individually. That means that the…Continue…
The FTC Warns Taxpayers About Tax Relief Companies
The Federal Trade Commission (FTC) is the nation’s consumer protection agency. It works to prevent fraudulent, deceptive and unfair business practices in the marketplace. It weighed in on the tax relief companies in an article posted on its website. Taxpayers should consider the FTC’s warnings before hiring a tax relief company. Unethical Tax Relief Practices…Continue…
Get a Notice CP2000 from the IRS? Here is What You Need to Know
No one wants to get a letter from the IRS. Even seeing the envelope is scary enough. The IRS’s Notice CP2000 is even scarier. The IRS issues the Notice CP2000 to alert you to changes it is making to you tax accounts. It almost always means that the IRS is increasing the amount of tax…Continue…
What You need to Know about the IRS Federal Tax Lien When Selling Property | Part 3
This is the third part of a three-part series of articles that explain what you need to know about the federal tax lien if you have unpaid tax debts. If you missed the prior two installments, you can find them here and here. As explained previously, the IRS’s federal tax lien can have a devastating…Continue…
What Property is Subject to the IRS’s Federal Tax Lien | Part Two
This is the second part of a three-part series of articles that explains what you need to know about the federal tax lien if you have unpaid tax debts. If you missed the first installment of this series, you can read it here. The IRS’s federal tax lien can have a devastating impact on your…Continue…