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Tag Archive for IRC

Tax Alert (USA) – US Tax Cuts & Jobs Act

On November 2, 2017, the US Congress House Ways and Means Committee unveiled the tax reform plan called the Tax Cuts & Jobs Act.  The bill aims to simplify the Internal Revenue Code and introduce tax savings for the average American family.  Although it is unlikely that the legislation will make it through Congress unscathed, it does provide a more detailed blueprint of the tax reforms that the citizens would like to enact.  Below are highlights of the proposed changes. Read more

Tax Reform Impacts The Research Tax Credit, Domestic Production Activities Deduction & Orphan Drug Credit

Lower Corporate Tax Rate
The law cuts the corporate tax rate from 35% to 21%. In effect, this cut increases the Research Credit’s net benefit by more than 21%, from its previous amount of 65% to the law’s 79%.

The 21% increase in the credit’s net value is due to IRC Section 280C(c). Read more

Tax Alert (USA) – US Tax Cuts & Jobs Act

On November 2, 2017, the US Congress House Ways and Means Committee unveiled the Republican tax reform plan called the Tax Cuts & Jobs Act.  The bill aims to simplify the Internal Revenue Code and introduce tax savings for the average American family.  Although it is unlikely that the legislation will make it through Congress unscathed, it does provide a more detailed blueprint of the tax reforms that the Republicans would like to enact.  Below are highlights of the proposed changes: Read more

Taxing Capital Gains Of Nonresident Aliens Residing In The US- The 183- Day Rule

Ephraim Moss, Tax Connections

For a unique group of foreign individuals (i.e., non-US citizens referred to in the tax world as “aliens”), living in the U.S. does not trigger “resident” status for tax purposes. These so-called “exempt” individuals include foreign studentsforeign scholars, and alien employees of foreign governments and of international organizations in the United States. U.S. tax law considers this lucky bunch to be exempt from counting days of presence in the United States for the purposes of determining whether they are resident aliens of the United States. Read more

Private Debt Collection: Recent Debts (Part 3 of 3)

In an earlier blog I discussed my concern about how the IRS’s private debt collection (PDC) program affects taxpayers who are likely experiencing economic hardship. In this blog, I want to share my concern that the IRS is not making good business decisions as it implements the PDC initiative.

Since 2004, Internal Revenue Code (IRC) § 6306 has authorized the IRS to outsource tax debts to private collection agencies (PCAs).

Read more

Why Is The U.S. Imposing Full Taxation On Canadians?

Why is the United States imposing full U.S. taxation on the Canadian incomes of Canadian citizens living in Canada?

The Internal Revenue Code mandates that ALL “individuals”, EXCEPT “non-resident aliens”, are subject to full taxation, on their WORLDWIDE income, under the Internal Revenue Code. The word “individuals” includes U.S. citizens regardless of where they live and regardless of whether they are citizens and residents of other countries where they also pay tax. This means that, by its plain terms, the United States imposes full taxation on the citizens and residents of other nations, because they are also (according to U.S. definitions) U.S. citizens. The United States is the only country in the world that has a definition of “tax residency that mandates full taxation based ONLY on citizenship. Read more

Gluten-Free Federal Tax Deduction

To be eligible to deduct the excess costs of a gluten-free diet under Internal Revenue Code Section 213, you must have a documented reason to require the observance of a gluten-free diet, along with a physician’s prescription to follow a gluten-free diet. This should provide sufficient documentation of eligibility.

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Did You Know That President Obama Could Obtain Donald Trump’s Tax Returns?

Ron Marini

In this presidential election, the Republican candidate Donald Trump steadfastly refuses to release his tax returns. This has caused political blogs to have a lively discussion regarding whether President Obama could request Donald Trump’s tax returns from the Internal Revenue Service (IRS)?

Read more

IRS issues Final Form 8971 & Instructions on How To Report the Final Estate Tax Value of a Property Transfered to Beneficiaries

For many years the IRS has had a problem verifying the basis of assets received by an heir from an estate. Within the last three or four years, the IRS has required brokerage houses and banks to supply it with the cost basis so that it could determine that the capital gain or loss on securities was correctly calculated.

There was no such parallel form within the estate tax forum. Section 1014 of the IRC gives the heirs a basis equal to a value reported on an estate tax return. Later, if an heir sells the inherited property, there is no transitional method for the IRS to Read more

Are Legal Expenses Tax Deductible?

A frequent question that arises is whether legal expenses are deductible. The answer to that question can be both yes and no and can be complicated depending upon the nature of the legal expense.

The Internal Revenue Code (IRC), which is the body of tax laws written by the United States (U.S.) Congress and approved by the president in office at the time the law is created, tells us that except as otherwise expressly provided, such as itemized deductions, no deduction shall be allowed for personal, living, or family expenses. The IRC also says that, in the case of an individual, deductions are allowed for all of the ordinary and necessary expenses paid or incurred during the taxable year:

For the production or collection of taxable income; Read more

Crimes Under The IRC — Part 2 of 2 – Crimes of Commission: Tax Perjury, Aiding Another and Hiding Assets

Knowingly filing a false tax return and aiding another to do so are violations of the IRC, Section 7206. Briefly summarized, those violations encompass:

• Tax perjury — knowingly signing a false tax return that is false
• Willfully aiding another person to commit tax fraud
• Hiding assets with the intent to evade or defeat the assessment of taxes or in connection with a tax settlement or compromise offer

Penalties are stiff

The law says that anyone convicted of the foregoing is guilty of a felony. An individual can face a fine of $250,000 ($500,000 in the case of a corporation or go to prison for not more Read more

Crimes Under The IRC — Part 1 of 2 – Failure To File, Supply Information or Pay Tax

Underpinning the vast power of the IRS to collect our tax money is the Internal Revenue Code (26 U.S.C), hereafter referred to as the IRC. Subtitle F, Chapter 75, Subchapter A, of the IRC lists the crimes and punishments for anyone convicted of violating our tax law.

The most common violations of the IRC are crimes of omission. The following is a brief discussion of Section 7203, Failure to File, Supply Information or Pay Tax.

Generally, there are four separate offenses described here:

1. Failure to pay the tax — The person is required by law to pay a tax at a time required by law and willfully failed to pay the tax. Willfulness simply means an intentional, voluntary violation of a known legal duty. Read more

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