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 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…

Can the IRS Foreclose on an Inheritance that is Jointly Owned?

What happens when someone inherits money from their parents, but they also owe the IRS? Can the IRS collect on the inherited assets? What if the taxpayer only inherited a fractional interest in the property? Can the IRS foreclose on the property to pay the back taxes? The court considered this in United States v.……

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