Straddle-Year Tax Debts in Bankruptcy: Does the King Get Paid First? [More with McGlinchey, Ep. 14]
You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more
Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more
El 1/1/24, el IRS actualizó su página de revocación o denegación de pasaporte en casos de ciertos impuestos no pagados. La Sección 7345 del Código de Rentas Internas requiere que el Departamento del Tesoro de los EE. UU....more
On 1/1/24, the IRS updated its Passport Revocation or Denial Page in cases of certain unpaid taxes. Section 7345 of the Internal Revenue Code requires the U.S. Department of the Treasury to notify the U.S. Department of...more
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
United States v. Firestone - In United States v. Firestone, the United States (Government or U.S.) sought to enforce a judgment against Defendant Omar Firestone (Omar) for outstanding tax liabilities related to the Estate of...more
It’s wonderful to be part of a successful business, especially in a strong economy. The owners are probably enjoying a more than just decent return on their investment and, in most cases, are getting along well enough. The...more
In a rare unanimous opinion, the U.S. Supreme Court recently confirmed that existing law allows the IRS to probe your bank records, without ever notifying you. Under the applicable statute, the Court concluded the IRS is not...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 24, 2023 – April 28, 2023...more
Summary: Petitioners, Willard Belton and Martha-Alexander Belton (Petitioners or Beltons) seeks review pursuant to section 7345(e), challenging the IRS’s certification to the Secretary of State that Petitioners had a...more
Summary: Petitioner, Blake M. Adams, seeks review pursuant to section 7345(e) of the IRS’s certification to the Secretary of State that Adams has a “seriously delinquent tax debt” related to tax years 2007, 2009, 2010, 2011,...more
In 2021, the Internal Revenue Service filed 212,251 Notices of Federal Tax Lien (“NFTLs”). To provide perspective, in 2019 (i.e., pre-COVID-19 pandemic), the IRS filed 543,604 NFTLs. The IRS is working on ramping up its...more
One of the little-known tools in the IRS collection tool belt is the ability to revoke a taxpayer’s passport where the taxpayer has a “seriously delinquent tax debt.”...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
Getting divorced is hard to begin with, but can be even more difficult when tax debts are owed to the Internal Revenue Service arising from jointly filed income tax returns. ...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
The Internal Revenue Service (“IRS”) faces many challenges when attempting to collect unpaid taxes from taxpayers with foreign assets who reside abroad (“international delinquent taxpayer” or “IDT”). Common obstacles include...more
Los Contribuyentes Estadounidenses con facturas de impuestos vencidas que han sido identificados por el IRS corren el riesgo de perder los privilegios de pasaporte de los EE. UU. ...more
Certain US Taxpayers that have been identified by IRS with overdue tax bills maybe at risk of losing US passport privileges. IRS has been trying to encourage US Taxpayers that are seriously behind on their taxes to pay what...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
Last week, the Internal Revenue Service (“IRS”) published another friendly reminder that it was recently vested with the authority to revoke passports and deny passport applications for those with “seriously delinquent tax...more
La habilidad del IRS de poder negar o revocar los Pasaportes de los Contribuyentes con "deuda tributaria gravemente morosa" es un problema serio que actualmente enfrentan los Contribuyentes de los Estados Unidos....more
Beginning January 1, 2018, the IRS will begin implementing Section 7345 of the Internal Revenue Code to certify tax debt to the State Department. This will allow the State Department to revoke or withhold the issuance of...more
According to the US Department of State, there are approximately nine (9) Million US passport holders living overseas. There continues to be a misimpression by certain US Taxpayers living overseas that they are not required...more
Two petitions for certiorari are pending before the Supreme Court of the United States, asking the Court to resolve the question of whether a tax return filed after an assessment by the Internal Revenue Service (IRS) is a...more