IRS provides guidance on new rules for employment tax levies Mike Habib, EA The IRS has issued interim guidance to its directors and collection area offices that explains when it is permissible to issue a levy to collect employment taxes without first giving the taxpayer a pre-levy collection due process…
Distressed asset trust transactions identified as listed transactions Mike Habib, EA In a Notice, the IRS has identified a distressed asset trust (DAT) transaction as a listed transaction under Reg. § 1.6011-4(b)(2), Code Sec. 6111 and Code Sec. 6112. In such a transaction, a tax-indifferent party contributes one or more…
Reconstructing Your Records Mike Habib, EA Reconstructing records after a disaster may be essential for tax purposes, getting federal assistance or insurance reimbursement. Records that you need to prove your loss may have been damaged or destroyed in a casualty. While it may not be easy, reconstructing your records may…
Direct from the IRS Mike Habib, EA Is an Offer in Compromise Right for You? Should the IRS determine that a taxpayer is unable to pay the liability in a lump sum or through an installment agreement and has exhausted the search for other payment arrangements the last option would…
As per the IRS Offer in Compromise Mike Habib, EA If taxpayers are unable to pay a tax debt in full and an installment agreement is not an option, they may be able to take advantage of an offer in compromise (OIC). Generally, an OIC should be viewed as a…
Most common questions by corporations and other business entities on 1099 reporting requirements. Below is a direct IRS response to frequently asked question on 1099 issues. Mike Habib, EA IRS provides further guidance on Form 1099 reporting Questions on Corporations. Generally, payments to corporations are not reported on Form 1099-MISC,…
IRS and treaty partners target Liechtenstein accounts Mike Habib, EA An IRS news release reports that IRS is initiating enforcement action involving more than 100 U.S. taxpayers to ensure proper income reporting and tax payment in connection with accounts in Liechtenstein. Observation: IRS is not alone in raising concerns about…
Supreme Court won’t review case holding that partner must pay tax on escrowed disputed funds Mike Habib, EA The Supreme Court has declined to review a decision of the U.S. Court of Appeals for the First Circuit that an individual who was a partner in a partnership had to pay…
As you probably know by now, I specialize in representing individuals and businesses before the IRS and any taxing authority. Mike Habib, EA IRS strengthened enforcement policies, along with their new and complex tax regulations, makes it essential to properly plan for and manage IRS examinations or collections efforts in…
Want to stop a wage levy or a bank levy? Read on…. Mike Habib, EA If you have not noticed, the IRS is getting more aggressive in their collection, and audit activities. Enforcement actions is at its highest level for years now! Here is the scoop directly from the IRS…