The tax assessment and collection process in most foreign countries is markedly different than the process in the U.S. These differences can present a number of challenges for U.S. citizens who reside in foreign countries. In Sotiropoulos v. Commissioner, T.C. Memo. 2017-75, the court considered one of these challenges, namely, how does one determine whether […]
The post U.S. Foreign Tax Credit Not Impacted by Repayment of Foreign Tax Refund appeared first on Houston Tax Attorney.
The tax assessment and collection process in most foreign countries is markedly different than the process in the U.S. These differences can present a number of challenges for U.S. citizens who reside in foreign countries. In Sotiropoulos v. Commissioner, T.C. Memo. 2017-75, the court considered one of these challenges, namely, how does one determine whether… Continue reading U.S. Foreign Tax Credit Not Impacted by Repayment of Foreign Tax Refund
The IRS challenges some tax positions by asserting that the transactions lack economic substance. This can allow the government to unwind or ignore transactions that comply with our tax laws if there is no legitimate business purpose for the transactions other than tax savings. There is a growing body of court cases that helps define […]
The post Court Considers Economic Substance in S Corp Transactions appeared first on Houston Tax Attorney.
The IRS challenges some tax positions by asserting that the transactions lack economic substance. This can allow the government to unwind or ignore transactions that comply with our tax laws if there is no legitimate business purpose for the transactions other than tax savings. There is a growing body of court cases that helps define… Continue reading Court Considers Economic Substance in S Corp Transactions
It can take a considerable amount of time to actually prepare and file a tax return. The IRS puts the time and cost at 13 hours and $210 dollars for the average income tax return. The numbers jump to 22 …
The funded research rules can present a number of challenges. The rules can also limit drastically the amount of research tax credits available to taxpayers (1) who are paid to perform research (it limits their wage and supply QREs) and …
If a Subchapter S corporation pays its shareholder’s personal expenses, can the payments be for the repayment of loans not subject to employment instead of wages subject to employment taxes? This is a common issue that has to be addressed when preparing S corp. tax returns. The IRS addressed this in AOD 2017-04, which was […]
The post IRS Says Personal Expenses Paid by S Corp. Not Loan Repayments appeared first on Houston Tax Attorney.
If a Subchapter S corporation pays its shareholders personal expenses, can the payments be for the repayment of loans not subject to employment instead of wages subject to employment taxes? This is a common issue that has to be addressed when preparing S corporation tax returns. The IRS addressed this in AOD 2017-04 disagreeing with… Continue reading IRS Says Personal Expenses Paid by S Corp. Not Loan Repayments
It is not clear as to what level of conduct justifies the imposition of the $100,000+ foreign bank account reporting (“FBAR”) civil tax penalty. In Bedrosian v. United States, No. 15-5853 (E.D. Pa. 2017), the court considered whether reckless conduct is sufficient given the facts presented in the case. The FBAR Civil Tax Penalty The […]
The post Reckless Conduct Sufficient for FBAR Civil Tax Penalty appeared first on Houston Tax Attorney.
It is not clear as to what level of conduct justifies the imposition of the $100,000+ foreign bank account reporting (“FBAR”) civil tax penalty. In Bedrosian v. United States, No. 15-5853 (E.D. Pa. 2017), the court considered whether reckless conduct is sufficient given the facts presented in the case. The FBAR Civil Tax Penalty The… Continue reading Reckless Conduct Sufficient for FBAR Civil Tax Penalty
