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Internal Revenue Service Liens

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Ervin Cohen & Jessup LLP

Can the IRS Obtain a Receiver to Help Collect Taxes Owed?

Q: I have a client who owes money to the IRS. While I know the IRS likely has a tax lien, my understanding was it just waits until a taxpayer’s property is sold and then gets paid out of escrow. Instead, here, the IRS has...more

Cadwalader, Wickersham & Taft LLP

IRS Private Letter Ruling Says CPACE Loans Qualify for REMIC Transactions

The IRS recently concluded that certain commercial property assessed clean energy (“CPACE”) assets are “obligations . . . secured by an interest in real property” under Code Section 860G(a)(3) in a private letter ruling...more

Freeman Law

Certificates of Discharge from IRS Liens

Freeman Law on

I previously posted about the process for requesting the subordination of an IRS lien – that post can be found here. However, as noted in that post, subordination is primarily useful in cases where a taxpayer intends to keep...more

Freeman Law

Subordination of IRS Liens

Freeman Law on

Subordination of IRS Liens - Outstanding IRS liabilities can create many issues for taxpayers. To pay all or part of a liability, taxpayers may be required to seek a loan using personal or real property as security. ...more

Holland & Knight LLP

How Can the Same Right Create 2 Separate Property Interests?

Holland & Knight LLP on

The Internal Revenue Service (IRS) can file a lien and levy on any and all of a taxpayer's property (and rights to property) regardless of how the property is held or titled. 26 U.S.C. § 6321. Whether the item is a taxpayer's...more

Rosenberg Martin Greenberg LLP

Internal Revenue Service Announces "People First Initiative" in the Wake of COVID-19

Initiative Temporarily Suspends Many Payment Requirements and Enforcement Actions - Earlier this week, the Internal Revenue Service (“the Service”) unveiled its new People First Initiative (“the Initiative”), an effort by...more

Rosenberg Martin Greenberg LLP

How the Internal Revenue Service's People First Initiative and Existing Collection Procedures Offer Additional Tax Resolution...

Distressed Businesses, the Unemployed, and Others Experiencing Financial  Hardship May Greatly Benefit if Action is Taken - Although the pandemic and related financial downturns have put many individuals and businesses on...more

Rosenberg Martin Greenberg LLP

Internal Revenue Service Announces “People First Initiative” In Wake of COVID-19

Initiative Temporarily Suspends Many Payment Requirements and Enforcement Actions Earlier this week, the Internal Revenue Service (“the Service”) unveiled its new People First Initiative (“the Initiative”), an effort by...more

McDermott Will & Emery

Seventh Circuit Upholds Lien Notice despite Incorrect Name

McDermott Will & Emery on

When you do not pay your taxes, the Internal Revenue Service (IRS) has the power to file a “lien” on your property under Internal Revenue Code section 6321. The lien attaches “upon all property and rights to property, whether...more

Burr & Forman

IRS Issues Guidance For Administration of Estate Tax Lien Discharge Requests

Burr & Forman on

In June of 2016, the Internal Revenue Service (IRS) changed its procedure for granting discharges of estate tax liens and implemented centralized handling of applications for discharge. Historically, Specialty Examination...more

Carlton Fields

Real Property, Financial Services & Title Insurance Update: Weeks Ending November 14 & 21, 2014

Carlton Fields on

REAL PROPERTY UPDATE - - Harris Act/Inverse Condemnation: dismissal was (1) improper as to landowners’ Harris Act claim because amendments to County’s land use plan were applied specifically to landowners’ property by...more

Proskauer Rose LLP

Wealth Management Update - June 2013

Proskauer Rose LLP on

The June § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.2%, which is a slight decrease from April's rate of 1.4% but remains the same as May's rate of 1.2%. The applicable federal...more

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