The corporation can be viewed from a number of different perspectives. One way is to view it as a group of people coming together to perform some business activity, with each having different relationships and risks in the arrangement. The role any one individual plays in the corporation may not be clearly defined. The owner-employee…
Tax Articles
Gift Tax Return for Wrong Year Starts IRS Statute of Limitations
The IRS receives a vast amount of information, which can make it challenging for them to act on all the information they possess. However, taxpayers have the ability to alert the IRS to potential tax issues and wait for the IRS’s response. The IRS generally cannot ignore information it has received. For example, in the…
The Collection Exception to Notice for IRS Summons
In tax disputes, the IRS holds a considerable advantage, as the law is often stacked in their favor, granting them broad collection powers. When all other avenues fail, the IRS summons becomes their primary tool for obtaining taxpayer records and information needed to assess and collect taxes. Despite the summons rules being unchanged for a…
Calculate Tax Loss for Criminal Tax Cases: Why It Matters
In the realm of criminal tax cases, time is of the essence. The criminal process operates at a markedly faster pace than the civil tax assessment process, creating a situation where defendants often overlook the precise amount of the tax loss they are accused of. While the tax-related details, including the actual amount owed, may…
Tax on Funds Received as an Intermediary Conduit
As tax attorneys in Houston, we often see investments made by local ethnic communities that are focused on investing overseas or raising money from overseas. This often involves those who immigrate to the U.S. from foreign countries, and do well in the U.S. financially. The investments are often made based on direct knowledge of opportunities…
Crypto Tax Loss & the Tax Loss Deduction Rules
Crypto tax loss refers to the capital losses incurred from selling or trading cryptocurrencies at a lower price than what was paid for them. These losses can be used to offset any gains earned throughout the year, reducing the taxpayer’s overall tax bill. The tax laws are clear that this type of investment loss is…
Tax Benefits of Charitable Remainder Trusts
Charitable giving is often an important part of an individual’s tax and estate planning strategy. One popular vehicle for charitable giving is a Charitable Remainder Trust (“CRT”), which can provide significant tax benefits for the donor and a stream of income for non-charitable beneficiaries during their lifetime. CRTs are valid, they can have some tax…
The Tax System as “a Game of Monopoly”
If you are a small business owner or an individual who works or even claimed a deduction for a child on your tax return, the IRS may go to great lengths to scrutinize your tax filings. This is particularly true if you are successful and earn any income. The more successful you are, the more…
Explaining Real Estate Profesional Status to IRS Employees
In the complex realm of the legal system, judges hold the vital responsibility of making impartial decisions, drawing from their wealth of life experiences. These experiences, in turn, have a profound influence on the judgments they render. This principle extends to other government officials as well, such as IRS agents, auditors, and attorneys, who are…
An Appraisal is Not Always Needed for a Casualty Loss Deduction
Casualty losses are often challenged by the IRS, as they meet the “large, unusual, or questionable” (“LUQ”) standard for pulling returns for audit. On audit, the IRS insists on an appraisal from a third party that shows the difference in fair market value before and after the casualty event. Even if an appraisal is provided…