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Tax Articles

Situations by which Docketed U.S. Tax Court Cases may be sent to Appeals for Settlement Consideration

In Notice 2015-72 the IRS proposes to update Rev. Proc. 87-24 regarding situations by which docketed U.S. Tax Court cases may be sent to Appeals for settlement consideration. This proposal: Intends to ensure that docketed cases are handled consistently nationwide. Clarifies that, except in rare circumstances, Counsel will refer cases docketed in Tax Court to Appeals for settlement consideration.…


2015 Depreciation Deduction Limitations for Passenger Vehicles

Understanding depreciation schedules including method and life expectancy is one of many areas of the Internal Revenue Code that separate the wide ranging ranks of the tax practitioner community. It never ceases to amaze me how many bush league practitioners and DIY-ers get this wrong. WHY? Because systematically there seems to be an over reliance on…


Different Sources of Income Matter FDAP v. ECI

One of the issues difficult for some of my international clients to grasp about the United States is its taxation of citizens and resident aliens alike on their worldwide income without any regard to where the income is earned. Taxing US citizens on their world wide income is one matter but taxing US resident aliens on…


The New IRS Audit Technique Guide for Entertainers is a Riveting Page Turner

I have many clients in the entertainment industry and appreciate them all. The ones that fly to Denver to meet with me are my favorite as they tend to be the most disciplined. You are applauded on and off the stage. Entertainers who invest their limited time learning about how income tax obligations impact their business…


2015 Listed Property Limits for Autos, Trucks & Vans

Tax practitioners often times tend to judge each other by the quality of our client’s respective asset lists and depreciation schedules. Truth is MANY practitioners get listed property limits WRONG because they simply do not understand the limits. Hence this post to help us all be on the same page! First things first however, as…


All SSA Disability Insurance Payments aka OASDI Benefits Now Subject to 100% Levy by IRS for Past Due Tax Assessments

This is really conflicting folks! On the one hand those of us who follow closely generally tend to believe that there is a LOT of rampant fraud in SSI Disability benefits practices these days but this news is going to really hurt a LOT of good people legitimately on SSI Disability that happen to have…


More on Marijuana Taxation: Beck v. Commissioner & Accounting for Excise Tax Paid – CCM 201531016

UGH! I vowed to stop writing about the tax implications of marijuana cultivation and distribution. The catholic guilt of a dysfunctional adolescence must be burning deep today as resisting the urge to come back for yet another round of punishment is futile. So here goes … Please be easy on me this time. I have two…


IRS Form 8833 – Treaty-Based Return Disclosure Under IRC 6114 – When MUST It Be Filed?

While the light of my life was off at a family wedding in Fargo, ND this past weekend a friend flew into town unexpectedly from Minnesota with a complimentary ticket to the Broncos Vikings football game. Of course this necessitated that I abandon my 13 and 11 year old children Sunday. Great game with good…


Coca Cola’s Recent IRS Statutory Notice of Deficiency – a Tipping Point in International Transfer Pricing Enforcement

In Coca Cola’s SEC 8-K filing last week we learned that the IRS issued a $3.3 Billion statutory notice of deficiency against the company as the result of a 5 year long transfer pricing audit covering tax years 2007-09. This is very BIG when it comes to enforcement of IRC 482 – Allocation of Income and Expenses Among Taxpayers because of…


Procedures for Requesting Competent Authority Assistance under US Tax Treaties

U.S. competent authority assistance is not necessarily contingent upon whether you sign an agreement with the IRS Examination function contrary to the assertions of some IRS Revenue Agents. Turns out this is important information for some US Taxpayers of international origin in battle with the IRS. Yes there are good and bad people EVERYWHERE, including some…