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Welcome to our legal news.
Welcome to our legal news.
Welcome to our legal news.
Welcome to our legal news.
Welcome to our legal news.
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IRS Letter 525: What It Is & Why It Matters
Letter 525 is not a final tax bill but rather a proposal of adjustments the IRS believes are necessary after reviewing a taxpayer’s return.
What is IRS Letter 2205-A?
IRS Letter 2205-A serves a single, but significant, function: it informs you that your individual tax return has been selected for audit.
What is IRS Letter 894?
IRS Letter 894 is a legally binding document informing you that the IRS has determined you owe additional tax.
IRS Letter CP503: What It Is and What You Should Do
IRS Letter CP503 is the IRS’s second written attempt to contact a taxpayer regarding an unpaid tax balance.
Understanding IRS Letter 5100
IRS Letter 5100 is a formal and final notice from the IRS Office of Appeals regarding a taxpayer’s challenge to a collection action.
What is IRS Letter CP11?
IRS Letter CP11 is a formal notification that the IRS has corrected a taxpayer’s return, resulting in a balance owed.
Understanding IRS Letter 566B
IRS Letter 566B signifies the start of a correspondence audit—a limited review of specific items on a taxpayer’s return.
IRS Notice CP504: What It Is and What To Do
IRS Notice CP504, also known as the Final Notice, informs a taxpayer that they have failed to address an outstanding federal tax debt.
Understanding IRS Notice CP12
IRS Notice CP12 is an official letter informing taxpayers that the IRS has made an automatic correction to their tax return.
IRS Letter 970: What It Is and What You Should Do
IRS Letter 970 is issued by the IRS Independent Office of Appeals to notify the taxpayer that their case has been assigned for review.
Understanding IRS Letter 531
IRS Letter 531 is final proposed finding at the administrative level and serves as a precursor to the Statutory Notice of Deficiency.
Letter 105C: What to Do When the IRS Denies Your Refund Claim
IRS Letter 105C serves as a formal notice that the IRS has denied your request for a tax refund or credit.
IRS Form 12256: What It Is and What You Should Do
Form 12256 enables taxpayers to formally cancel their request for a Collection Due Process or Equivalent Hearing.
Understanding IRS Letter 1277
IRS Letter 1277 is a formal notification issued by the IRS to inform a taxpayer that their request for a refund or penalty abatement has been denied.
IRS Letter 3172: What It Is and What You Should Do
IRS Letter 3172 is an official communication from the IRS informing you that a Federal Tax Lien has been publicly filed.
Understanding IRS Notice CP523
IRS Notice CP523 is a formal notification that an existing installment agreement is in default and is subject to termination.
IRS Letter 3219: What It Is and What You Should Do
IRS Letter 3219 is a formal notice that grants you time to resolve the issue or exercise your right to dispute the IRS’s position in court.
IRS Letter 5248: Essential Information for Taxpayers
IRS Letter 5248 informs taxpayers that the IRS has identified discrepancies in reported income.
IRS Letter 2202: What It Is and What You Should Do
IRS Letter 2202 is issued when the IRS intends to adjust items on your return based on a compliance review or examination.
Understanding IRS Letter 566S
IRS Letter 566S is usually sent when the IRS is reviewing your tax return or has identified discrepancies needing clarification.
Can You Deduct Breast Implants on Your Taxes?
In the landmark 1994 case Hess v. Commissioner, an exotic dancer won the right to deduct her breast augmentation surgeries as a legitimate business expense.
IRS Letter CP05A: What It Is & What You Should Know
IRS Letter CP05A signals that the IRS is conducting a more detailed review of your return before releasing any potential refund.
Understanding IRS Letter 4800C
Receiving IRS Letter 4800C can be unsettling, but it’s essential to understand that this letter is a proposed change, not a final determination
IRS Letter CP501: What It Is and What You Should Do
IRS Letter CP501 informs you that you owe taxes to the Internal Revenue Service.
IRS Letter 12C: Legal Implications and Guidance for Taxpayers
The IRS issues Letter 12C when a taxpayer’s Form 1040 cannot be processed due to missing, incomplete, or inconsistent information.
Understanding IRS Letter 1058
Letter 1058 is the IRS’s final warning before initiating enforced collection actions such as wage garnishments, bank levies, or seizing property.
Breaking Down IRS Letter 5216C
Receiving IRS Letter 5216C signifies that the IRS has received your individual tax return but cannot verify your identity.
IRS Notice CP14: Legal Implications and Guidance for Taxpayers
The IRS issues Notice CP14, titled “Amount Due – First Notice,” to inform taxpayers of a balance owed on their tax account.
IRS Letter CP504B: What it Means and How to Respond
Receiving IRS Letter CP504B can be alarming—but ignoring it is far worse.
Federal Remittance Tax: Legal Considerations and Implications
The U.S. House of Representatives passed the “One Big Beautiful Bill Act,” which, among other provisions, proposes the implementation of a federal remittance tax.
What Is IRS Notice CP49 and What Does It Mean for Your Refund?
Notice CP49 This notice informs the taxpayer that their refund has been applied toward an outstanding tax debt.
Do You Qualify for an Offer in Compromise?
Offer in Compromise (OIC), a tax resolution tool that allows individuals to settle their tax debt for less than the full amount owed
Form 8938: Who must file, and how to file
Form 8938, “Statement of Specified Foreign Financial Assets,”
Stewart Weston Case: Denial of Deduction for Travel Expenses
Denial of Deduction for Travel Expenses
🚨🚨🚨Is the BOI no longer required: Analysis of the Nationwide Injunction on the Corporate Transparency Act🚨🚨🚨
In a major legal development, the United States District Court for the Eastern District of Texas has temporarily halted the enforcement of the Corporate Transparency Act (CTA) through a preliminary injunction.
Challenges in Proving Reasonable Cause: Budde v. Commissioner Case
This case highlights the stringent standards upheld by the IRS and Tax Court when evaluating taxpayers’ defenses against accuracy-related penalties, particularly for negligence or substantial understatement of income tax.
BOI Report: What Is Substantial Control?
concept of substantial control and its implications for reporting companies under the Corporate Transparency Act (CTA).
Deductions Rejected by Tax Court: The Atighi Case
standards taxpayers must meet to substantiate deductions and accurately report taxable income
Tax Year-End Planning Strategies: Prepayment of Expenses
As the year-end approaches, taxpayers and professionals should focus on strategies to optimize their tax position for 2024. Among the most effective tools available is the prepayment of expenses. This strategy enables taxpayers to accelerate deductions, reduce taxable income, and manage cash flow efficiently.
Proposed Regulations on Previously Taxed Earnings and Profits (PTEP) – Overview
On November 29, 2024, the U.S. Department of the Treasury and the IRS issued proposed regulations addressing the taxation of previously taxed earnings and profits (PTEP).
Cracking the BOI Report: Tax IDs for Disregarded Entities in BOI Reports
What type of tax identification number (TIN) should be reported by a disregarded entity?
Denial of Tax-Exempt Status:Students and Academics for Free Expression Case
This case underscores the importance of a complete and well-documented application process for organizations seeking recognition as 501(c)(3)
Maximizing the Lifetime Learning Credit: A Guide for Taxpayers
This article provides a detailed overview of the Lifetime Learning Credit (LLC), eligibility requirements, and tips for maximizing this benefit.
How to Report 1099-K for 2024?
This article outlines the thresholds for 1099-K issuance, provides examples of common issues such as misclassified income, and highlights some reporting practices, including Schedule C filing for business-related income.
🚨🚨How to Claim a Dependent Already Claimed? New IRS Guidelines🚨🚨
By using an Identity Protection Personal Identification Number (IP PIN), taxpayers can now e-file duplicate dependent claims, streamlining the process and reducing delays.
BOI Compliance: Who is the Company Applicant?
Who qualifies as a company applicant of a reporting company
⚠️New Tax Form to Report Restricted Stock – Form 15620⚠️
The IRS recently released Form 15620, a streamlined document for taxpayers to file an 83(b) election when acquiring restricted stock.
Understanding the 1040-NR: Filing for Nonresident Aliens
Nonresident aliens (NRAs) file Form 1040-NR, the U.S. Nonresident Alien Income Tax Return, to report income derived from U.S. sources
BOI Address Reporting: Key Insights for Foreign and U.S.-Based Companies
Which address to report for beneficial owners and what to do if a reporting company lacks a principal place of business in the United States?
How to File a Tax Court Petition: A Legal Overview
This article delves into the mechanics and procedureal requirements of filing a Tax Court petition
BOI Reporting Penalties: Who Pays and How?
This article outlines the consequences for failing to comply with BOI reporting requirements
Reporting BOI to FinCEN: Key Deadlines and Update Requirements
The Corporate Transparency Act (CTA) requires reporting companies to disclose beneficial ownership information (BOI) to FinCEN. Understanding these deadlines is critical for compliance.
Foreign Pensions are Foreign Trusts under U.S. tax law
Foreign pensions often present complex tax issues for U.S. taxpayers due to their classification as foreign trusts under the Internal Revenue Code (IRC). These classifications come with stringent reporting obligations, including Form 3520, Form 8938, and in some cases, Form 8621
No 25% Owner? Understanding BOI Filing Obligations
If a Company Does Not Have a 25% Owner, Does It Still Need to File a BOI Report?
How to File a Missed FBAR?
This article provides a detailed analysis of how to address missed FBAR filings and explains the distinction between willful and non-willful noncompliance, which determines the applicability of two main resolution process, including the Voluntary Disclosure Practice of the IRS and the Streamlined Filing Compliance Procedures.
Expiring Tax Provisions Under the Tax Cuts and Jobs Act: What Tax Practitioners Need to Know
Several key provisions of the TCJA are set to expire at the end of 2025. Understanding changes and potential strategies to address them will help practitioners effectively guide clients through the upcoming transition
DBAs and BOI Compliance: Do You Really Need to File?
whether a sole proprietorship operating under a “Doing Business As” (DBA) name must submit a Beneficial Ownership Information (BOI) Report.
Innocent Spouse Relief: A Lifeline for Unfair Tax Liabilities
Innocent Spouse Relief provides critical protection for taxpayers who face tax liabilities resulting from the actions of their current or former spouse.
🧟 “Zombie” 🧟 or Inactive Companies for Purposes of the BOI Report: Practical Example
Practical application of the inactive entity exemption established in the Corporate Transparency Act. An entity deemed an “inactive company” is exempted from filing the Beneficial Ownership Information (BOI) Report.
Federal Tax Liens: What Every Tax Practitioner Should Know
Understanding the mechanics of a federal tax lien, and strategies to address them can help practitioners guide clients effectively.
Frivolous Position Penalty Under IRC § 6673: Swanson Case
This case serves as a reminder of the Tax Court’s strict stance on taxpayers who present baseless arguments and the application of the frivolous position penalty.
How to Request Tax Relief for Disaster-Affected Clients: A Guide for Tax Practitioners
The IRS provides tax relief measures for individuals and businesses affected by federally declared disasters, extending deadlines for filing returns and making payments. Tax practitioners play a crucial role in securing these extensions for clients impacted by natural disasters. This guide details the specific steps practitioners should follow to request tax relief for clients in disaster area and on behalf of clients located outside of the disaster area when necessary records are held within the impacted area.
Can ITIN Holders Be Shareholders in an S-Corp?
ITIN holders who meet the IRS’s Substantial Presence Test and qualify as U.S. tax residents are eligible to be S-corp shareholders
Denial of Deduction for Damaged Inventory: IQ Holdings Case
Taxpayers often face obstacles in justifying deductions. IQ Holdings, Inc. v. Commissioner examines the Tax Court’s recent opinion on the evidentiary requirements for deductions related to inventory adjustments for damages, charitable donations and net operating losses. This case serves as a reminder of the strict documentation standards maintained by the IRS and the Tax Court when evaluating inventory adjustments for damages and other types of deductions claimed by a corporation.
Fraud Loss Deduction: Shaut Case
Taxpayers face challenges in substantiating deductions for fraud losses. This article discusses how the Tax Court has addressed the evidentiary requirements for deducting losses and expenses related to investment fraud (fraud losses).
IRS Announces Change in Penalty Policy for Forms 3520 and 3520-A
The IRS has announced a major change in penalties for late-filed IRS Forms 3520 and 3520-A, both of which are essential for U.S. taxpayers who transact with foreign trusts or receive large gifts from foreign individuals.
Unreported Income Problems: Tibin v. IRS Case
Taxpayers have problems with unreported income. In Tibin v. Commissioner of Internal Revenue, Yagoub Tibin, sole owner of TM Transportation, LLC, sought a redetermination of a 2020 federal income tax deficiency determined by the IRS. The IRS alleged that Tibin had unreported income earned in his transportation business and disallowed certain business expense deductions.
New US rule targeting real estate money laundering slated for early 2024
A long-awaited rule meant to clamp down on money laundering through the U.S. real estate market is likely to be proposed in early 2024, according to the U.S. Treasury Department. The new regulations may require real estate professionals to report the...
Investigators worldwide continue to open ‘Pandora’s Box’
The Pandora Papers exposed the financial secrets of powerful people in more than 100 countries, leading to a worldwide crackdown on tax dodgers, money launderers and the white-collar professionals who enable them. From India to Germany, Peru, the U.K. and beyond, two...
Administrative Law
From India to Germany, Peru, the U.K. and beyond, two years after the International Consortium of Investigative Journalists published the Pandora Papers, authorities worldwide continue to investigate, prosecute and legislate against tax evaders, money launderers and...
Last News
IRS Letter 525: What It Is & Why It Matters
When the IRS completes an examination of a tax return, it often communicates its findings through formal correspondence. One of the most common notices issued at this stage is IRS Letter 525, also known as the “30-Day Letter.” This letter is not a final tax bill but...
What is IRS Letter 2205-A?
Few things generate as much anxiety for taxpayers as receiving a letter from the IRS. Among the most concerning is Letter 2205-A, which signals the beginning of an audit process for individual taxpayers. Unlike a routine notice of balance due or a request for...