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 […]
Category: Tax Controversy
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 […]
Lately, we have been following the corporate maneuvers designed to reduce U.S. corporate tax burdens. Unlike the recent Kinder Morgan move that will only affect some investors, inversion deals will bring broader unwelcome tax surprises for legacy investors. Medtronic’s acquisition of Covidien provides an example of how an inversion deal […]
The Internal Revenue Service recently issued a generally positive private letter ruling regarding Windstream’s plan to spin part of its company into a real estate investment trust. In an unusual move, the company will move its fiber optics and copper networks along with real estate into the REIT and then […]
On July 17, 2014, the House passed legislation called the “America Gives More Act of 2014” (H.R. 4719). The bill contained “tax extenders” for two charitable tax breaks that could expire, but are normally renewed for one or two years at a time. In addition, there were two new ideas. […]
In his influential book “The Wealth of Nations,” published in 1776, the Enlightenment thinker Adam Smith wrote about how human beings like to “truck and barter.” Of course, the “truck and barter” diction seems a bit dated today. But the phenomenon Smith pointed to remains as timely as ever. Humans […]
Let’s pick up the thread of a discussion we began earlier this spring about the tax treatment of individual retirement accounts (IRAs). Traditional IRAs and Roth IRAs have historically had significant differences. As we noted in our March 31 post, for example, contributions to a traditional IRA are still tax […]
Tax considerations have long played a role in businesses’ choices of entity. This was true even a generation ago, when the main forms of organization were relatively few: sole proprietorships, partnerships and corporations. It is even more so today, especially with the popularity of relatively new forms of organization: limited […]