As per the IRS Offer in Compromise
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 last resort after taxpayers have explored all other available payment options. The IRS resolves less than one percent of all balance due accounts through the OIC program.
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.
IRS provides further guidance on Form 1099 reporting
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.
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.
As you probably know by now, I specialize in representing individuals and businesses before the IRS and any taxing authority.
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 a proactive manner. Applying new dispute resolution procedures and best practices is critical to managing IRS examinations or collections, resolving disputes at the earliest point, and containing administrative and tax costs. The Tax Controversy services we offer are:
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!
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:
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.
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 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.
Tax Relief Blog