Business owners have choices in how to fund their corporations. Should they contribute cash? Property? Perhaps a promissory note? There may be some benefit of using a promissory note. You get stock in your company without immediately parting with cash …
Tax Articles
Accounting for Interest Deductions as a Tax Planning Option
Tax attorneys frequently come from an accounting background. This may seem like an unrelated skill, but it often plays a pivotal role in effective tax planning. The ability to navigate revenue and expenses and debits and credits not only ensures accura…
Texas Taxes: Is an Owner Liable for Business Taxes?
When one thinks of Texas and taxes, the idea that Texas does not have an income tax may come to mind. This is true. Texas does not currently have an income tax. This does not mean that Texas does not collect taxes. Texas collects taxes–and a lot of taxes. This includes everything from property taxes… Continue reading Texas Taxes: Is an Owner Liable for Business Taxes?
The IRS’s Ability to Collect Foreign Assets
Those who have unpaid taxes owed to the IRS may have assets located in foreign countries. If the IRS cannot collect from assets located in the United States, it may seek to collect from foreign assets. This is often a very difficult task. While the IRS has a number of tools to collect from foreign… Continue reading The IRS’s Ability to Collect Foreign Assets
Planning for Commercial Solar Tax Credits
The solar tax credit can significantly reduce Federal income taxes. Congress has recently reaffirmed its desire to spur these investments to curb reliance on foreign energy and to help the environment. As with most tax incentives, such as the research tax credit, there are a number of rules that have to be followed to be… Continue reading Planning for Commercial Solar Tax Credits
A New Beginning for Innocent Spouse Relief
The Taxpayer First Act of 2019 made several changes that impact how tax cases are handled. We are just now seeing some of these changes play out administratively and in court. The recent Bacigalupi v. Commissioner, Docket No. 20480-21 (U.S. Tax Court 2022) is an example of this. It is an innocent spouse case that… Continue reading A New Beginning for Innocent Spouse Relief
Adjustments Stemming from IRS Settlements
Generally, when it comes to civil matters, state and Federal law includes various “statutes of limitations” and “discovery rules.” The statute of limitations rules say that a claim has to be filed within a certain time period. The discovery rules say that the time period for the statute starts to run when the claim is… Continue reading Adjustments Stemming from IRS Settlements
Court: Complex Tax + Professional Advice = No Tax Penalty
We know that we can take steps to minimize our taxes. Our tax laws allow for this and, on review, the courts have made this clear. Tax penalties are usually the problem with taking tax positions in situations that are not entirely clear. Taxpayers who find themselves having to make decisions in these gray areas… Continue reading Court: Complex Tax + Professional Advice = No Tax Penalty
Partnerships Have to Maintain Accurate Capital Accounts
One of the tax benefits of partnerships is that they are flexible. The parties can agree to differing terms and the values and dollars associated with those terms can be trued-up in subsequent years. The allocation of profit and loss provisions provides an example. Depending on their agreement, the parties can allocate profits and losses… Continue reading Partnerships Have to Maintain Accurate Capital Accounts
Reasonable Cause & Reporting Charitable Donations
The IRS is tasked with enforcing our tax laws. The task should be to ensure “substantial compliance” by taxpayers. But all too often the audit process is nothing more than the IRS examining a handful of go-to-adjustment issues. These go-to-adjustment issues involve tax laws that Congress passed that leave room for interpretation. These issues often… Continue reading Reasonable Cause & Reporting Charitable Donations