Tax Relief

UK Payroll Issues

April 13, 2009 | Mike Habib, EA

U.K. revises rules on how short-term business trips by employees from other countries are taxed [HMRC website]: The United Kingdom’s tax agency, Her Majesty’s Revenue and Customs (HMRC), has amended its Employment Procedures (EP) manual with respect to the taxation of income earned by employees from other countries who are working in the U.K. on a short-term basis. In most circumstances, if employees from other countries perform duties in the U.K., they are responsible for U.K. income tax on a “pay-as-you-earn” (PAYE) basis, regardless of how long they are in the U.K. However, employees who are residents of a country with which the UK has a treaty agreement are not subject to income tax in the U.K. if the resident is in the U.K. for less than 183 days of the taxable year, and certain other conditions are met. Prior to the amendment to the EP manual, when determining the 183 day limit, a partial day counted as a partial day, not a full day. Therefore, someone spending three consecutive 8 hour days working in the UK was regarded as having spent one day in the U.K. Effective April 6, 2009, each partial day spent in the U.K. is now considered a full day. Therefore, someone spending three consecutive 8 hour days working in the U.K. is now regarded as having spent three days in the U.K. for purposes of the 183 day limit. For further information on the U.K. payroll tax system, see http://www.hmrc.gov.uk/employers

—

For payroll tax problem resolution contact the tax firm of Mike Habib, EA at 877-788-2937 or at myirstaxrelief.com

Innocent Spouse Relief

April 9, 2009 | Mike Habib, EA

Tax Court finds regs imposing time limit on request for relief from joint and several liability invalid Lantz, (2009) 132 TC No. 8

Mike Habib, EA Tax Relief & IRS Tax Help

The Tax Court has concluded that Reg. § 1.6015-5(b)(1), which provides that a spouse must request relief under Code Sec. 6015(f) no later than two years from the first collection activity against the spouse, is invalid.

IRS Tax Help

April 9, 2009 | Mike Habib, EA

Recession Offers the Best Opportunity to Obtain Tax Relief

American taxpayers are afforded the best IRS tax help in this financial crisis.

Pasadena, CA –(PR.com) — The current financial crisis is the best time to get IRS tax help. Just recently, the IRS has announced that it will adopt a more humane approach to taxpayers who are currently faced with issues such as increasing medical bills, heavy dependence on the assistance of Social Security or even recent job loss. According to the Internal Revenue Service, these are the criteria that can make taxpayers eligible for certain tax breaks. The IRS is also willing to make certain adjustments for those who have problems with unfiled tax returns or unpaid back taxes.

Making Work Pay Credit

April 7, 2009 | Mike Habib, EA

IRS posts Q&As on the Making Work Pay Credit

Making Work Pay Credit: Questions and Answers, IRS Web Site

IRS has posted a number of questions and answers (Q&As) on the Making Work Pay Credit (MWPC) on its web site. They are grouped into four categories: general issues, Form W-4, new withholding tables, and economic recovery payments. The most widely applicable information from each of the four categories is summarized below.

G-20 Accounting Reform

April 7, 2009 | Mike Habib, EA

G-20 includes accounting reform in proposed overhaul of market regulation

Mike Habib, EA Tax Relief & Tax Problem Resolution

Summary: The heads of the leading 20 world economies called on accounting standard-setters to revise fair value guidance and adopt a single, global set of global accounting rules. The leaders also agreed to regulate hedge funds, increase oversight of credit rating agencies, set up systemic risk regulators, and tighten the limits on executive pay.

Payroll Tax Relief

April 7, 2009 | Mike Habib, EA

Roundup of recent employment tax related cases of interest

Mike Habib, EA Tax Relief & Tax Problem Resolution

Federal courts have recently issued rulings on: (1) whether medical residents may qualify for the student FICA exception, (2) whether an employee’s embezzlement was reasonable cause for failing to remit withholding taxes, and (3) whether the sole owner of a limited liability company (LLC) may be held liable for the LLC’s unpaid employment taxes.

Settle with IRS

April 2, 2009 | Mike Habib, EA

Most Tax Procrastinating City in America

Settle with IRS and resolve your tax problems by contacting the tax firm of Mike Habib, EA at 877-788-2937 or online at myirstaxrelief.com

As reported by Intuit, maker of TurboTax.

1031 Tax Problem

April 1, 2009 | Mike Habib, EA

Like-kind-exchange related party rule triggered gain recognition despite use of qualified intermediary

Ocmulgee Fields, Inc. (2009) 132 TC No. 6

Mike Habib, EA Tax Relief Services

IRS Tax Help for Expats

April 1, 2009 | Mike Habib, EA

Adverse conditions may allow certain U.S. citizens to claim foreign earned income and housing cost exclusions [Rev Proc 2009-22]:

Individuals who were forced to leave certain foreign countries in 2008 because of adverse conditions may still qualify as bona fide residents of that country for purposes of the IRC §911 foreign income tax exclusion. Under IRC §911(a), qualified individuals may exclude foreign earned income and housing expenses from their gross income for tax purposes.

To qualify for the exclusion, an individual must prove that he has lived in a foreign country for at least 330 full days during any period of 12 consecutive months. However, if instances of war, civil unrest, or other adverse conditions force an individual to leave a country before the 330-day requirement is met, that individual can still qualify for the exclusion if he can prove that he would have otherwise stayed in the country.

Subsidiary employment tax problem

March 31, 2009 | Mike Habib, EA

Subsidiary’s employment tax liability cannot be collected from the parent corporation [Chief Counsel Advice 200913052]:

The IRS Office of Chief Council has expressed its opinion in a new Chief Council Advice (CCA) that the employment tax liability of a subsidiary corporation in a consolidated group cannot be collected from the parent corporation.

A “subsidiary” is defined under Reg. § 1.1502-1(c) as a corporation that is a member of a consolidated group, but is not the common parent of the group. In a consolidated group, (1) the parent corporation must directly own at least 80% of the total voting power and 80% of the total value of the stock in at least one other “includible” corporation in the group, and (2) one or more of the other includible corporations in the group must directly own at least 80% of the stock (by vote or value) in each of the remaining includible corporations.