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 […]
Category: Tax Controversy
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 […]
In an expected weeklong trial, the family of Carl Pohlad, a billionaire real estate developer and owner of the Minnesota Twins, will argue that the Internal Revenue Service estate tax calculations overstate Pohlad’s remaining interest in the baseball team at his death. The IRS argues the estate owes approximately $255 […]
Burger King Worldwide Inc. is in talks to buy Canadian coffee-and-doughnut chain Tim Hortons Inc. in a move that would relocate the hamburger seller’s headquarters to Canada. The two are planning to create a new company. Should the deal be successful, the new entity will be the third-largest quick-service restaurant […]