In the first part of this post, we began discussing the issue of worker classification for purposes of paying (or avoiding) payroll taxes. The issue of worker vs. contractor has been around for years, but is as timely as ever. As we noted, this is because revenue agencies have been […]
Category: Tax Controversy
In the first part of this post, we discussed the possibility of getting a preliminary (but not binding) ruling from the IRS about an upcoming transaction with significant tax consequences. As we explained last week, a private letter ruling may be used for that purpose. But what about a transaction […]
If you have a complicated transaction coming up for your business, there may be tax consequences that you would like to get more clarity on before moving forward. Or, you may have a tax question from your past that you’d like to resolve. In such cases, is it possible to […]
In the first part of this post, we outlined the basic considerations involved in defining when an organization is “closely held” for tax purposes. In this part of the post, we will look in more detail at how the Tax Court and the IRS have differed recently in interpreting and […]
Closely held businesses can sometimes seem synonymous with their owners. But for tax purposes, there are important respects in which that is not true. In this post, then, we will ask and address the following question: How does the IRS define a closely held corporation? The question is timely because […]
There doesn’t seem to be a great deal of dispute among the politicos in Washington about whether the U.S. tax code needs reform or not. Just about everyone agrees it needs fixing. The question then becomes, just what is likely to be possible considering the current makeup of Congress and […]
Federal and state tax laws are often in alignment with each other on the basic structure of deductions, exemptions and so on. But how does federal tax law take account of the fact that federal taxes may be affected by differences in state tax structure? In Texas, this is a […]
IRS in 2009. This program has been beneficial to many taxpayers in resolving tax debt and avoiding federal tax liens. But as the Treasury Inspector General for Tax Administration (TIGTA) found in a recent report, there are several ways in which the Fresh Start program could be improved. In this […]
Employers face difficult decisions regarding the hiring and classification of workers. Having to pay employment taxes for employees is only one of many factors involved in these decisions. Other factors include employee preferences (some workers actually prefer the flexibility of contractor status) and the complicated nature of the distinction between […]
An offer in compromise (OIC) is a useful option for many people in resolving tax debt. If the IRS accepts your offer, the OIC procedure allows you to settle your debt for less than the full amount you owed. The OIC program keeps changing, however, and it is important to […]