Posts by Category: Income Tax

IRS Announces New Procedures for U.S. Citizens Residing Overseas Who Have Not Filed Tax Returns and Reported Income

The IRS has long been aware of U.S. taxpayers living overseas who have not filed federal income tax returns or Reports of Foreign Bank and Financial Accounts (“FBARs”).  Earlier this year, the IRS announced the reopening of its successful Offshore … finish reading IRS Announces New Procedures for U.S. Citizens Residing Overseas Who Have Not Filed Tax Returns and Reported Income

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First Circuit Ruling May Provide More Flexibility for Conservation Easement Donors in Dealing With Lenders

The Court of Appeals for the First Circuit, in Kaufman v. Shulman, Docket No. 11-2017P-01A (1st Cir., July 19, 2012), reversed a Tax Court decision siding with the IRS which had disallowed a couple’s conservation easement deduction.  The Tax Court … finish reading First Circuit Ruling May Provide More Flexibility for Conservation Easement Donors in Dealing With Lenders

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The Importance of a Qualified Appraisal for Conservation Easements

Landowners may be allowed a federal income tax deduction for the contribution of a conservation easement restricting donated property.  A qualified conservation contribution is a donation of a qualified real property interest to a qualified organization which is exclusively used … finish reading The Importance of a Qualified Appraisal for Conservation Easements

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Fourth Circuit Court of Appeals Rejects IRS Transferee Liability Theory

On May 31, 2012 the Fourth Circuit Court of Appeals issued its opinion in the case of Starnes v. Commissioner, upholding a decision of the United States Tax Court which determined that the former shareholders of a corporation were not … finish reading Fourth Circuit Court of Appeals Rejects IRS Transferee Liability Theory

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IRS Announces More Flexible Offer-in-Compromise Terms to Help More Struggling Taxpayers Make a Fresh Start

On Monday, May 21, 2012, the Internal Revenue Service announced another expansion of its “Fresh Start” initiative by offering more flexible terms to its Offer in Compromise (“OIC”) program with the goal of assisting more financially distressed taxpayers in resolving … finish reading IRS Announces More Flexible Offer-in-Compromise Terms to Help More Struggling Taxpayers Make a Fresh Start

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IRS Revises Streamlined Installment Agreement Program

There are five general methods of resolving an assessed federal tax liability: (1) full payment, (2) payment through installments under a written agreement, (3) placing an account into currently uncollectible status, (4) an offer in compromise, and (5) bankruptcy.  Installment … finish reading IRS Revises Streamlined Installment Agreement Program

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Reinstatement for Tax-Exempt Organizations whose Exemption Status was Automatically Revoked by the IRS

Many individuals and business entities create charitable organizations to serve the needs of a specific group of persons or a specific community with a need for a type of service.  Most charitable organizations undertake the arduous task of applying for … finish reading Reinstatement for Tax-Exempt Organizations whose Exemption Status was Automatically Revoked by the IRS

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South Carolina Conservation Easement Tax Credit Transfers

A landowner who donates a conservation easement to a qualifying organization can benefit from state tax incentives, in addition to the available federal income tax deduction.  South Carolina provides an important transferable income tax credit for landowners who donate a … finish reading South Carolina Conservation Easement Tax Credit Transfers

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IRS Announces New 2012 IRS Foreign Bank Account Voluntary Disclosure Program

The IRS recently announced the reopening of its successful Offshore Voluntary Disclosure Program (OVDP) effective January 9, 2012.  The IRS also announced that its two prior foreign bank account disclosure initiatives, in 2009 and 2011, have brought in more than … finish reading IRS Announces New 2012 IRS Foreign Bank Account Voluntary Disclosure Program

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Employer Must Comply with IRS Levy to Garnish Wages and May Not Challenge the Validity of the Levy

The IRS has the authority to attach a tax lien to property of the taxpayer once the IRS assesses a federal tax liability against the taxpayer and issues notice of an intention to levy.  If the taxpayer fails to resolve … finish reading Employer Must Comply with IRS Levy to Garnish Wages and May Not Challenge the Validity of the Levy

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The Joy of Reporting Income Earned in Foreign Countries to the IRS

U.S. citizens that work or receive income from abroad are subject to U.S. income taxes on foreign income.  The tax is applicable regardless of where U.S. citizens reside.  U.S. taxpayers receiving foreign income must file an income tax return with … finish reading The Joy of Reporting Income Earned in Foreign Countries to the IRS

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The IRS Offer in Compromise: A Way to Resolve Outstanding Federal Tax Liabilities

Generally, there are four methods of resolving an assessed federal tax liability: (1) full payment, (2) payment through installments under a written agreement, (3) an offer in compromise, and (4) bankruptcy.  The IRS also has the authority to temporarily suspend … finish reading The IRS Offer in Compromise: A Way to Resolve Outstanding Federal Tax Liabilities

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Management and Executive Compensation in Nonprofit Organizations: Part 2

To minimize the risk of engaging in an excess benefit transaction related to compensation paid in connection with an organization exempt from income tax under Section 501(c)(3) of the Internal Revenue Code of 1986, as amended (an “Exempt Organization”), the … finish reading Management and Executive Compensation in Nonprofit Organizations: Part 2

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Management and Executive Compensation in Nonprofit Organizations: Part One

Many of us have both the privilege and the responsibility of serving as a board member or as a trustee of a charitable organization. Many of these charitable groups are organizations exempt from income tax as organizations described in Section … finish reading Management and Executive Compensation in Nonprofit Organizations: Part One

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IRS Announces Favorable Rules for Employer Provided Telephones

On September 14, 2011, the Internal Revenue Service (the “IRS”) issued Notice 2011-72, 2011-38 IRB 407 which provides guidelines on the treatment of cellular telephones or other similar telecommunications equipment (hereinafter collectively “cell phones”) that employers provide to their employees … finish reading IRS Announces Favorable Rules for Employer Provided Telephones

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Portability: A New Estate Planning Tool

The passage of the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010, on December 17, 2010, introduced the new estate and gift tax savings concept of “portability,” which is effective for estates of decedents dying after December … finish reading Portability: A New Estate Planning Tool

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IRS Reverses Position On Equitable Innocent Spouse Relief Claims

On July 25, 2011, the Internal Revenue Service issued IRS Notice 2011-170, 2011-32 I.R.B. 135 and announced that it will help taxpayers who request innocent spouse relief by eliminating the two-year time limit that applies to equitable relief requests.  However, … finish reading IRS Reverses Position On Equitable Innocent Spouse Relief Claims

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United States Tax Court Agrees with Taxpayer and Finds Reasonable Cause to Abate Employment Tax Penalties

This post was co-authored by Adam Landy and Erik Doerring. On July 5, 2011, the United States Tax Court abated penalties assessed by the IRS against a business taxpayer for failure to pay its employment taxes. The Tax Court agreed … finish reading United States Tax Court Agrees with Taxpayer and Finds Reasonable Cause to Abate Employment Tax Penalties

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Spring 2011 Statistics of Income Bulletin Now Available

IR-2011-67, June 14, 2011 — The IRS released the spring 2011 issue of the Statistics of Income Bulletin.

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