John Stancil

Having survived tax season for one more year, I was struck by how complex our tax code really is. I’ve been preparing taxes for over 40 years, yet I ran into several provisions that I had not previously encountered. I am fully aware that there is much wrong with the code, that there are some major overhauls needed. In the midst of all this complexity, it struck me that there are provisions in the code which are not big deals, but are head scratchers. Why are these things in the code? Eliminating them can go a long way toward helping the middle-class taxpayer.

Read More

Marco Rossi

With the Budget Law for fiscal year 2017, Italy enacted a new flat tax for Italian first-time residents. The flat tax amounts to euro 100,000 regardless of the amount of taxable income. Foreign source income is completely exempt from tax, while domestic source income is taxed under the normal rules (graduated tax rates on income brackets generally applying to all resident taxpayers).

Read More

I have heard questions about expired refunds. Let me summarize. “I faced a hardship and didn’t file tax returns for several years. Now, I learn that I cannot get my refunds for all those years. Can you help?”

Read More

Ephraim Moss

In a recently published Chief Counsel Advice, the IRS chief counsel’s office offered advice to taxpayers participating in its amnesty programs regarding the issue of whether refunds for past overpayments of tax can be used to offset additional taxes or penalties triggered under the program.

Before we get to the advice, let’s first review the amnesty programs that could potentially be affected by the conclusions made in the published advice.

Read More

John Richardson

Previously, we have look at the tax treaty tiebreaker and how it relates to taxation of Subpart F and PFIC income as well as eligibility for streamlined offshore procedures. This is another in a series of posts on the tax treaty tiebreaker (which is a standard provision in most U.S. tax treaties).

Read More

Barry Fowler

It looks as if taxpayers have to be wary and skeptical even when they send their personal information to the IRS. This government agency is supposed to be trusted with our personal information. Especially at a time when criminals are posing as IRS agents over the telephone, through email, through our employers human resources departments and through schools you would think the IRS itself would be safe. But no!

Read More

Lisa Nason

The Internal Revenue Service (IRS) has announced the launch of a new online application to help taxpayers. The new tool, available on IRS.gov, allows taxpayers to view their tax account balance online. The balance includes any amount owed for tax, as well as penalties and interest for each tax year. Once you view your balance, you can take advantage of online payment options, including direct pay, pay by debit or credit card and Online Payment Agreement.

Read More

We ran an article from John Dundon yesterday mentioning the deadline to file From 7004 was March 15th. If you have not been able to to file that form for an extension due to the storm, the IRS is deciding to grant you extra time.

Read More

Ephraim Moss

Recently, the IRS announced that it will focus its audit efforts this year on 13 particular compliance issues, which touch on large business and international activities. This issue-focused effort contrasts with the more broad-based approach that the IRS has previously taken with respect to auditing taxpayers.

Read More

Hale Stewart

A CFC is a foreign corporation where a U.S. shareholder owns “more than” 50% of the offshore company. Practitioners quickly noted the 50% ownership requirement and correctly deduced that, if a non-U.S. shareholder owned the remaining 50%, the foreign corporation could escape being a CFC.

Read More

Annette Nellen

Our tax filing systems are not perfect! How does the IRS or a state tax agency really know if the person filing a return is the true owner of the taxpayer identification number used? In IRS Publication 1345, on procedures for authorized e-file providers, the IRS states that if the preparer/e-filer does not know the client, they should get two forms of verification (ideally picture IDs that include the client’s name and address (page 11 of Pub 1345)). That should help. What else is needed?

Read More

Barry Fowler

So, you lived through 2016 even though you find yourself in the unenviable position of either not having filed your taxes for several years or owing the IRS back taxes that you just don’t know how to pay, and the fees and penalties keep accruing. This article is for you.

Read More