The time limits for filing amended tax returns can present a number of difficult questions. This is particularly true when tax attributes, such as foreign tax credits and net operating loss deductions, are carried back to prior years. The carryback to one prior year can result in carrybacks to one or more years prior to… Continue reading Amending Tax Returns for FTC and NOL Carrybacks
Tax Articles
Court Says Rent Income from S Corp Not Subject to Self-Employment Taxes
In Martin v. Commissioner, 149 T.C. 12 (2017), the court concluded that S corporation shareholders can avoid self-employment taxes by holding their farming operations in their S corporation. While the court case considered farming operations, its holdi…
Court Says Rent Income from S Corp Not Subject to Self-Employment Taxes
In Martin v. Commissioner, 149 T.C. 12 (2017), the court concluded that S corporation shareholders can avoid self-employment taxes by holding their farming operations in their S corporation. While the court case considered farming operations, its holding is not limited to farming operations. The case provides authority shareholders may cite in support of similar but… Continue reading Court Says Rent Income from S Corp Not Subject to Self-Employment Taxes
Court Denies IRS Injunction in Employment Tax Dispute
It is common for the IRS to make various demands on businesses that are undergoing employment tax audits or businesess that are trying to deal with employment tax collection issues. One common demand is that the taxpayer immediately start complying …
New IRS Directive for Auditing Current Year Wage QREs
The IRS’s LB&I Commissioner released a new directive about how certain qualified research expenses will be audited. We have already received inquiries as to whether clients should attempt to comply with the directive. For most clients, the answer is a …
Court Denies IRS Injunction in Employment Tax Dispute
It is common for the IRS to make various demands on businesses that are undergoing employment tax audits or businesess that are trying to deal with employment tax collection issues. One common demand is that the taxpayer immediately start complying with the employment tax laws. But what if the taxpayer cannot comply, perhaps due to… Continue reading Court Denies IRS Injunction in Employment Tax Dispute
Can the IRS Keep My Refund to Pay My Spouses Tax Debts?
Will you receive a tax refund from the IRS if you marry someone who owes back taxes to the IRS? If the IRS keeps your refund for the current year to pay your spouse’s premarital tax debts, what rights do …
U.S. Treasury Says IRS Not Using Information from Foreign Governments
It wasn’t long ago that the IRS was completely in the dark as to what information taxpayers and others were reporting to foreign governments. The IRS would never show up on U.S. audit with information obtained from foreign governments. We …
U.S. Treasury Says IRS Not Using Information from Foreign Governments
It wasn’t long ago that the IRS was completely in the dark as to what information taxpayers and others were reporting to foreign governments. The IRS would never show up on U.S. audit with information obtained from foreign governments. We do see this on audits occasionally, but it is still a rare occurrence. A recent… Continue reading U.S. Treasury Says IRS Not Using Information from Foreign Governments
Court Says Deduction for Tax Loss Not Allowed for Worthless Debt
Tax losses for worthless debts often trigger IRS audits. On audit, it is common practice for the IRS to disallow the losses based on the debt not being worthless, the amount of the loss not being correct, and that the …..
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