By law, the IRS certifies taxpayers with “seriously delinquent” tax debts to the Department of State affecting passport status and renewal when certain conditions or thresholds are met. The IRS will send a Notice called a...more
The Saskatchewan Court of Appeal has confirmed that the Supreme Court of Canada’s decision in Orphan Well Association v. Grant Thornton Ltd., 2019 SCC 5 [Redwater], applies in Saskatchewan. The Court of Appeal also affirmed...more
The U.S. Supreme Court rules that the IRS does not need to provide notice to innocent bank account holders when the summonses are issued in aid of collection of a delinquent taxpayer’s tax assessment. ...more
As discussed in our previous blog post, Unpaid Municipal Taxes Will Impact New AER Licenses and License Transfers, the Alberta Minister of Energy released Ministerial Order 043/2023 (the Order) on March 16, 2023. The Order...more
The Court of King's Bench for Saskatchewan has rejected another attempt by a rural municipality to gain priority in an oil and gas receivership. This follows the recent Alberta Decision in Orphan Well Association v Trident...more
On March 20, 2023, the Alberta Minister of Energy, Peter Guthrie, released ministerial order 043/2023 (the Order). The Order, authorized pursuant to the Responsible Energy Development Act, requires the Alberta Energy...more
In The Bank of Nova Scotia v The Queen, the Tax Court of Canada (TCC) considered how to calculate arrears interest on an audit adjustment that is offset by a loss carryback. ...more
Many people end up owing the IRS for many reasons and there are various options to resolve your tax debt. Some of the options include an offer in compromise, installment agreement, or currently non-collectible status....more
Many taxpayers (if not all) would agree with the sentiment expressed on a wall plaque that recently caught my eye: “Dear IRS: I would like to cancel my subscription. Please remove my name from your mailing list.” That feeling...more
The New Jersey Department of Labor (NJ DOL) billed Uber Technologies, Inc. and a subsidiary $650 million for past-due taxes, interest, and penalties due to an alleged misclassification of its drivers as independent...more
(SC 20131) Department of Transportation v. White Oak Corporation (collateral estoppel and statutory off-sets) - In this decision, the Supreme Court concluded that the State could reduce the amount of damages it was ordered...more
The Fixing America’s Surface Transportation (FAST) Act, signed into law December 4, 2015, created new Internal Revenue Code § 7345 which requires the IRS to notify the United States State Department when an individual is...more
Pasaporte - La capacidad del IRS para negar o revocar los Pasaportes de los Contribuyentes con "deuda tributaria gravemente morosa mayor de $50,000" es un problema abrumante que actualmente enfrentan los Contribuyentes de...more
Passport - The IRS ability to deny or revoke the Passports of Taxpayers with “seriously delinquent tax debt greater than $50,000” is a distressing problem currently being encountered by U.S. Taxpayers...more
Where a business does not pay its federal employment and/or unemployment taxes, and continues in operation, the IRS will utilize administrative measures, including tax liens and levies, to collect the unpaid taxes....more
El Departamento de Estado de los EE.UU esta requerido a denegar la solicitud de pasaporte de un individuo y está autorizado a revocar o limitar un pasaporte existente si el IRS certifica que el individuo tiene una deuda...more
The U.S Department of State is required to deny an individual’s passport application and is authorized to revoke or limit an existing passport if the IRS has certified that the individual has seriously delinquent federal tax...more
Breakingviews on Broadcom’s threat to Qualcomm’s board in the form of a slate of 11 director nominees for the company it has, so far, unsuccessfully attempted to purchase....more
Uber’s Board of Directors has officially voted to realign the power balance at the company, reducing the clout of ousted CEO Travis Kalanick, and setting the stage for a stock sale to SoftBank. Oh yeah, and prepping for that...more
If an individual or business owes federal taxes and does not have the current ability to pay these taxes, the IRS can consider placing the account into “currently not collectible” (CNC) status. If placed in CNC status, a...more
Sometimes seniors find themselves owing past-due federal taxes they cannot afford to pay. Although notices from the IRS can be especially frightening, there are solutions. ...more
The Third Circuit Court of Appeals sitting in Pennsylvania recently issued a precedential decision that interpreted the definition of a “named insured” under a tax delinquency statute to encompass tenants of a property even...more
The IRS has recently renewed the use of private companies to assist with the collection of some of its past due accounts. Although according to the National Treasury Employees Union, each of the prior attempts to use private...more
The Internal Revenue Service has released additional guidance about its new and controversial “Private Debt Collection” program — which requires the use of private debt collectors to collect certain delinquent tax debts —...more
On September 26, 2016, the IRS announced its plans for the private collection of certain federal tax debts beginning next spring. The announcement identified the following four (4) contractors that the IRS selected to carry...more