Tax Relief BlogMost 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.
IRS provides further guidance on Form 1099 reporting
Articles Posted in IRS Notice
IRS targets offshore bank accounts Tax Haven Abuse
IRS and treaty partners target Liechtenstein accounts
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.
Partnership tax vs. Individual tax return Problem Resolution
Supreme Court won’t review case holding that partner must pay tax on escrowed disputed funds
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 tax on his distributive share of the partnership’s income, notwithstanding that the partnership’s receipts had been placed in escrow pending the outcome of a suit by the individual against the other partner.
Wage Garnishment? Bank Levy? Save your paycheck and bank account
Want to stop a wage levy or a bank levy? Read on….
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!
IRS Tax Audit due to Tax Return Preparer Fraud
Tax Return Preparer Fraud
Since I recently represented an innocent couple who were victims of Tax Return Preparer Fraud, and successfully helped them in their audit, I thought you might be interested in the info below.
Per the IRS:
Economic Stimulus Rebate Check to be sent by the IRS
In an effort to stimulate the economy, the recently-enacted Economic Stimulus Act of 2008 requires the U.S. Treasury to send rebate checks to eligible individuals.
Who qualifies for rebates, how they are calculated, and what, if anything extra, needs to be done to get one.
You’ve probably heard that the government is going to be sending rebate checks to most Americans in an effort to stimulate the economy. This letter explains, among other items, who gets rebates, how they are calculated, how higher income can reduce or eliminate a rebate, and what, if anything extra, you’ll need to do to get one.
Capital gain tax on disputed sale in shareholder’s forced buyout
Tax problem with capital gain taxes, S Corp capital gain tax problem
Ninth Circuit holds that gain was recognized on disputed sale in shareholder’s forced buyout
Glenn Hightower v. Comm., (CA9 2/12/2008)
IRS gets tougher on VPFC variable prepaid forward contracts with share lending arrangements
IRS gets tougher on variable prepaid forward contracts with share lending arrangements Variable Prepaid Forward Contracts Incorporating Share Lending Arrangements
An IRS coordinated issue paper for all industries concludes that variable prepaid forward contract (VPFC) transactions that incorporate a share lending or similar agreement permitting the counterparty to borrow or dispose of the pledged shares results in a current taxable sale of the underlying stock.
Observation: VPFCs are sophisticated tools used by wealthy individuals with large stock gains who want to cash out some of their shares but defer the tax until a later year.
IRS SFR Substitute For Return Unfiled Tax Returns Back Taxes Owed
Final substitute return regs adopt temporary and proposed regs with one minor change
T.D. 9380, 2/12/2008; Reg. § 301.6020-1
In 2005, IRS issued temporary (also issued as proposed regs) that broadened the scope of when IRS-prepared substitute returns (SFR) are valid. Specifically, the temporary regs provide that a document or set of documents (including a Form 13496, Code Sec. 6020(b) Certification) signed by an authorized IRS officer or employee is a “return” under Code Sec. 6020(b) if it identifies the taxpayer by name and taxpayer identification number, contains sufficient information to compute his tax liability, and purports to be a return. IRS has now adopted the temporary and proposed regs as final regs with one minor change.
Tax Court found that it could hear challenge to frivolous return penalty before rejecting summary judgment in favor of IRS
IRS tax problem, IRS penalty, IRS Tax court ruling in favor of taxpayer
Tax Court found that it could hear challenge to frivolous return penalty before rejecting summary judgment in favor of IRS
Callahan (2008), 130 TC No. 3
