News & Analysis as of

Income Taxes Internal Revenue Service

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

Tax Payment Plans: What Do You Do? (Part 3)

by McNair Law Firm, P.A. on

If an individual or business owes federal taxes and does not have the current ability to pay these taxes, the IRS can “seller-finance” and offer a payment plan with the taxpayer. The primary benefit of a payment plan is that...more

When A Partner May Not Be Acting As A Partner

by Farrell Fritz, P.C. on

It is not uncommon for a partner to engage in a business transaction with a partnership of which he is a member. If the partner engages in a transaction with his partnership other than in his capacity as a partner, he will be...more

Failure to Disclose Adjusted Basis on Disclosure Form Costs Taxpayer $33M+ Charitable Deduction

by Charles (Chuck) Rubin on

Under Treas. Regs. §1.170A-13, taxpayers making substantial noncash charitable contributions are required to disclose information regarding the contribution on Form 8283. ...more

Cumplimiento Fiscal Internacional

by Foodman CPAs & Advisors on

Detectar, disuadir y responder al incumplimiento internacional son desafíos clave que enfrentan las autoridades tributarias de todo el mundo. El incumplimiento fiscal internacional es un problema significativo reconocido por...more

Unfiled Tax Returns: What Do You Do? (Part 2)

by McNair Law Firm, P.A. on

The United States has a voluntary income tax reporting system. U.S. citizens, permanent residents, and businesses here must annually file income tax returns with the IRS, reporting their “worldwide income”, deductions, and...more

Gain Realized By Non-Resident Foreign Partner Upon The Sale Of Its Interest In A U.S. Partnership Is Not U.S.-Source Income Unless...

by Roetzel & Andress on

In Grecian Magnesite Mining, Industrial & Shipping Co., SA, v. Commissioner of Internal Revenue (filed on July 13, 2017), the United States Tax Court overturned Revenue Ruling 91-32 (which had been relied on since 1991) and...more

Can Foreign Partners Now Exit Partnerships Tax Free?

by Bracewell LLP on

In Grecian Magnesite Mining v. Commissioner (“Grecian Magnesite”) the Tax Court held that a non-U.S. partner's gain from the redemption of its partnership interest was neither U.S. source income nor income effectively...more

Are you a Taxpayer identified by IRS for not Reporting Offshore Financial Assets?

by Foodman CPAs & Advisors on

Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful. The definition of “Willful" or "non-willful” in Taxpayer’s conduct...more

Controlled Foreign Corporation: Neither A Lender, Guarantor, Nor Pledgor Be?

by Farrell Fritz, P.C. on

Last week, we considered the U.S. taxation of a closely held foreign corporation that owned a minority interest in a partnership that was engaged in business in the U.S. This week, we turn our sights to the U.S. taxation of a...more

You Owe IRS Taxes: What Do You Do? (Part 1)

by McNair Law Firm, P.A. on

Many individuals and businesses owe taxes to the IRS, or they have not filed their tax returns or both. While the IRS may be the most powerful creditor in the world, there are solutions. This is Part I of a series addressing...more

Here is what you need to know about a Domestic Voluntary Disclosure (DVD)

by Foodman CPAs & Advisors on

DVD can be an option for a Taxpayer without foreign financial accounts or foreign financial issues. It is a choice for Taxpayers that are out of domestic compliance, want to come into compliance and inoculate as much as...more

Foreigner’s Sale of Partnership Interest: Not Taxable

by Farrell Fritz, P.C. on

Coming to America- Whether they are acquiring an interest in U.S. real property or in a U.S. operating company, foreigners seek to structure their U.S. investments in a tax-efficient manner, so as to reduce their U.S....more

No Rest For The Weary: Offshore Tax Evasion Crackdown Continues With Flurry Of Mid-Summer Activity

by Fox Rothschild LLP on

Dashing any thought that they were taking a hiatus from investigating and prosecuting taxpayers with secret offshore bank accounts and the bankers that helped them, the Justice Department and Internal Revenue Service have...more

SCORE! for the Boston Bruins – Jacobs v. Commissioner

Like Napolean recognizing that an army marches on its stomach, the owners of the Boston Bruins know a hockey team needs to be well-fed to ensure optimal performance on game day. So, when the Bruins go on the road to play...more

Related-Party Provisions Prevent Deduction by S Corp Shareholders - Tax Update Volume 2017, Issue 4

by Pepper Hamilton LLP on

Many routine transactions occur between related parties, including the payment or accrual of interest on indebtedness, license fees, salary or benefits to employees and/or shareholders, and trade invoices. The Tax Court...more

Golly Gee—the U.S. Tax Court Ruled That the Cost of a Taxpayer's Microsoft Xbox 360 and a Nintendo Wii Used by His Children Did...

by Garvey Schubert Barer on

In 2015, the U.S. Tax Court issued its ruling in the case of David W. Laudon v. Commissioner, TC Summary Option 2015-54 (2015). The case may not raise or even resolve any novel tax issues, but it reminds us of what is...more

Recent U.S. Tax Court Case Reverses Long Held IRS Position Regarding Taxation of Sales of Partnership Interests by Foreign...

by Locke Lord LLP on

Following the inauguration of the new administration in January 2017, many investors were anticipating the passage of a transformative tax reform bill at some point in 2017. Although legislative tax reform is seemingly...more

The US Tax Court Rejects IRS Position That Non-US Partners Are Taxed on Sales of Partnership Interests

by Shearman & Sterling LLP on

The US Tax Court earlier this month issued a decision that rejected a 25-year old IRS Revenue Ruling and held that gain from the sale or other disposition by a non-US person of an interest in a partnership that is engaged in...more

Disposition of U.S. Partnership Interest Will Not Result in Effectively Connected Income to Foreign Partner

by Charles (Chuck) Rubin on

What happens when a foreign individual or corporation sells an interest in a partnership that is engaged in a U.S. trade or business? The Internal Revenue Code does not directly answer this question - the answer lies at the...more

Newsflash: Tax Court Reverses IRS Revenue Ruling

by Dechert LLP on

A recent U.S. Tax Court case, Grecian Magnesite (149 T.C. No. 3, July 13, 2017), has declared invalid the long-standing U.S. government position that a non-U.S. person’s sale of an interest in a partnership (in this case, a...more

Alert: New Tax Court Decision Opens the Door for Tax Planning for Non-US Investors into US LLCs

by Cooley LLP on

On July 13, 2017, the US Tax Court issued a decision which may provide non-US investors more flexibility and potentially better tax outcomes with respect to structuring their investments into US LLCs and partnerships....more

Texas Data Thieves Sentenced To Prison For $1.8 Million Fraud Scheme

by King & Spalding on

On June 30, 2017, the U.S. Attorney’s Office for the Southern District of Texas announced the sentencing of two men convicted of conspiring to claim up to $1.8 million in fraudulent income tax refunds from the Internal...more

BEWARE! Impact of New Tax Rules on Your Family Limited Partnership

by Strasburger & Price, LLP on

Family limited partnerships (“FLPs”) are a common estate planning technique. They permit centralized asset management, provide liability protection, and create a mechanism by which one generation can transfer wealth to the...more

Update to Guide on U.S. Taxation of Nonresident Aliens

by Charles (Chuck) Rubin on

I first wrote a simplified guide to U.S. taxation of nonresident aliens before the Internet and emails. The first few editions were printed and mailed out to persons on our firm's mailing list. Eventually, I circulated it by...more

IRS is Looking more like a “Self-Serve” Financial Provider while still Targeting Collections

by Foodman CPAs & Advisors on

Since 2011, IRS has undergone $900 million in budget cuts and has reduced its number of auditors by approximately 25%. Nonetheless, IRS has its eye on the “collections” ball. The Agency has recently benefited from...more

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