The Chartwell Chronicles: Medicare & Medicaid
Advancing Agriculture: Security Interests and Article 9 Challenges (Part 2)
Podcast - Credit Funds: Make-Wholes and Cramdowns: Understanding the Recent Second Circuit Momentive Decision
Connecticut Collections: How to get paid if you are owed money? Part 3: Steps in the Collection Process
Construction Lien Law: What You Need to Know to Protect Your Company
Bill on Bankruptcy: The Market's Unquenchable Thirst for Junk
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
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
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
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
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
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
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
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
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
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
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
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