When a joint return is filed and only one spouse owes a past-due amount, the other spouse can be considered an injured spouse. An injured spouse claim is different from an innocent spouse claim, since it uses Form 8379 to request an allocation of the tax overpayment attributed to each spouse, whereas an innocent spouse claim uses Form 8857 to request relief from joint liability for items of the other spouse (or former spouse) that were reported incorrectly on the joint return.
In Lindsay Manor Nursing Home, Inc. v. Commissioner, 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.
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.
Non-Disclosure Agreements (NDA), also known as confidentiality agreements, are used to protect a business's proprietary information. An NDA is a legally binding contract between a business and another party who agree to keep specific information, such as patents, recipes, marketing research and trade secrets, confidential. The definition in the NDA needs to be as specific as possible, but without disclosing any confidential information. Typically, an NDA is between an employer and employee, but a business may also ask for one in a transaction with another business.
During the 2017 tax season, the MD Comptroller suspended a total of 54 tax preparers who have been involved in potentially fraudulent behavior.
On May 5th Glen E. Frost wrote a letter, on behalf of the American Citizens Abroad, to IRS Commissioner John Koskinen in regards to private collection firms based in the United States collecting debts of U.S. taxpayers with foreign addresses.
In 2015 the Fixing America’s Surface Transportation Act ("FAST Act") was established to provide long-term funding for surface transportation infrastructure planning and investment. Included in this new law was a section allowing the State Department to refuse to issue or renew a passport for a seriously delinquent taxpayer.
Donald Trump has proposed to make several tax changes when he enters office in January. It is important to examine the possible tax changes that could result from the new plan so that taxpayers are aware of the potential advantages and disadvantages the new tax plan may give them.
Jessica Frase Marine, Esq.
When a taxpayer receives a notice from the IRS proposing an additional assessment of tax, the taxpayer can often work administratively with the IRS to resolve the dispute. However, many times, the taxpayer and IRS are not able to come to an agreement. In those instances, there are four different forums which can be utilized to litigate a Federal civil tax case: the United States Tax Court, United States District Courts, the United States Court of Federal Claims, and United States Bankruptcy Courts.
Glen Frost is Advocating for a Same Country Exemption from FATCA Reporting for Citizens Living Abroad
Glen Frost is advocating for a same country exemption from FATCA reporting for citizens living abroad: