The IRS refocused its efforts on international tax issues about ten years ago. This effort has yielded scores of transfer pricing, foreign tax credit, and similar tax disputes. While not as prominent as transfer pricing and foreign tax credit disputes, the IRS has also focused on U.S.-sourced income that is not reported. The IRS has……
Category: Tax Law
Funding a Business: LLC Capital Contribution vs. Loan
Taxpayers have several choices to make when starting a business. One of these choices is how to fund the business. They can fund the business with capital contributions or debt (or a combination thereof). The IRS and courts will usually follow the method the taxpayer uses. Many taxpayers do not consciously decide this issue. They……
The Contract for Deed Can Avoid IRS Liens
The contract for deed can provide a way to transfer ownership of property to someone who owes back taxes to the IRS, while preserving the right to avoid the IRS lien and IRS foreclosure. Real estate investors and those doing real estate deals may prefer these sales as they can often be made at higher……
When the IRS Sends Mail to the Wrong Address
The IRS sends out a lot of letters. It usually uses the U.S. Postal Service to send these letters. The volume of letters is so high that the IRS may be the U.S. Postal Service’s largest customer. These IRS letters are often required. These requirements are found in the Code. The requirement that the IRS……
Can the IRS Waive Compliance With Tax Rules?
What happens if you make a technical foot fault while working with the IRS? Say you miss a deadline or a filing requirement. Can the IRS waive compliance with the deadline or requirement? IRS personnel will often say that they cannot. But in reality, the IRS can waive most procedural requirements. The authority for this……
Tax on Damages for Loss of Consortium
Those who receive damages from physical injuries or sickness are not required to pay tax on the damage award or settlement. That is the general rule. But what about ancillary claims by others? What about a lawsuit for physical damage that also includes a claim for the injured parties spouse? What if the taxpayer-husband was injured and the……
Settle Taxes & Keep Right to Dispute Open
If there is any doubt as to whether a taxpayer is liable for income taxes, there is a good chance that the IRS will agree to settle for less. The IRS Office of Appeals is tasked with doing just that. IRS appeals settlements are usually all or nothing. If the taxpayer does not accept the……
How to Contest an IRS Settlement Agreement
What happens if the IRS enters into a settlement agreement for your tax liability and then, later, it takes a position that is inconsistent with the agreement? For example, can the IRS agree that an expense is deductible by your business only to say that the same is expense is taxable income to you as……
What Counts as Tax Advice?
What if a CPA talks to you and tells you about a tax law? You have received tax advice, right? What if a CPA sends you a letter or email saying the same thing he would have said to you in person, had he spoke to you in person? Probably still tax advice, no? What……