Tax Topics

In Inc. v. Commissioner, Manor Nursing Home, 148 T.C. No. 9 (Mar. 23, 2017), where a corporate taxpayer sought release from a proposed levy because it would create an economic hardship, the Tax Court concluded that limiting economic hardship relief to individuals is a permissible interpretation of the statute. Taxpayer, a nursing home facility in […]

In an article in The Washington Post, Glen Frost was quoted when he talked about a “mystery business.” The business found an ingenious and legal way of making a 10 percent return on their money. The business just made sure to significantly overpay its estimated taxes, triggering a law that required the city to refund […]

Kristin LeClair Zurowski Generally, the first step in setting up a business is the choice of entity. While state laws govern the formation of entities, Federal law dictates the treatment of entities for Federal tax purposes. Additional considerations should be liability, control, and exit strategy. The most common entity types are: Sole Proprietorship – An […]

Competing laws can make for confusing situations. For many people in the Washington, D.C., area, trying to find the balance becomes something of a way of life. This may be particularly true for green card holders who have financial ties that reach around the globe. On one hand, the current political turmoil over immigration makes […]

U.S. taxpayers with more than $10,000 in a foreign financial account at any time during the calendar year are required to report foreign financial interests on Financial Crimes Enforcement Network (FinCEN) Form 114, Report of Foreign Bank and Financial Accounts (FBAR). Since the financial crisis in 2008, the government has increased its attention to overseas […]

Leanne Fryer Broyles, Esq. Most people are familiar with the concept of a “spendthrift”- a person who is recklessly wasteful with his or her spending. While the spendthrift trust bears the name of the type of person for whom it was designed, its modern purpose is much broader. Anyone leaving substantial means to their beneficiaries […]

Late last month Treasury Secretary Steven Mnuchin announced what he said was one of the largest sanctions actions every taken by Treasury’s Office of Foreign Assets Control (OFAC). The sanctions are aimed at 271 employees of the agency of the Syrian government believed to have been involved in chemical weapons attacks. These individuals are now […]

Living outside the U.S. can have many benefits, both cultural and financial. But in terms of complying with U.S. tax laws, expatriates carry more burdens, not fewer, than taxpayers who live in the U.S. In this post, we will use a Q & A format to address the issue of tax compliance for U.S. citizens […]

The IRS has been remarkably successful in getting people to enter its limited-amnesty program for undisclosed offshore accounts. In the first part of this post, we took note of some of the reasons for this. The Offshore Voluntary Disclosure Program (OVDP) has seemed to offer the opportunity to reduce the risk of criminal prosecution for […]

The ongoing IRS enforcement crackdown on offshore accounts has been remarkably lucrative for Uncle Sam. Since the crackdown began in 2009, it has driven more than 100,000 taxpayers into IRS programs to resolve their offshore compliance issues and generated upwards of $10 billion in back taxes, interest and penalties from those taxpayers. But are more […]