Tax Implications of US Expatriation; Internal Revenue Code 877A

I was brought in on another interesting file this week involving a US Citizen seeking expatriating that I was strongly advised to run away from by my mentors and friends simply because it is easy to paint a picture of prospective

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Posted in Expatriation, FBAR, International Tax

New Information on US – Canada Income Tax Treaty

There are a LOT of people from Canada in Denver, Colorado where I spend the majority of my time as a student of the US tax code.  Many dual citizens got stung by the reasonably new US FBAR tax laws

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Posted in Canada, International Tax, IRB 2006-49

What is an FTE? What is a Seasonal Employee?

My friend, confidant, mentor and expert in the procedural ramifications of ObamaCare, Debbie Nash of D. Nash & Associates, got to talking with me about some of the nuances of this legislation and our discussion quickly digressed into what the

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Posted in Affordable Care Act, Business Expense, Employee Business Expense, FTE, Medical Expenses, Medicare, Small Business, Sub-chapter S, Tax Credit, Tax Deductible Expenses, Tax Guidance & Preparation

Tax Considerations When Supporting Parents

As I have been helping my Mom transition into life as a widow many interesting facts have begun to resonate. Particularly intriguing for me today under Regs. §1.2-2(b)(4) parent(s) can be claimed as a dependent if you meet the usual support, citizenship,

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Posted in Deductible Expense, Dependent, Family, Filing Status, Health Insurance, Tax Deductible Expenses, Tax Filing Status, Tax Guidance & Preparation

Basic Steps to Avoiding Probate

As many of you know that follow this blog my father recently passed away and I've been called upon to settle his financial affairs. My biggest fear is probate and after studying the tax code I have grown to be of

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Posted in Estate Tax, Generation Skipping Transfer Tax, Gift Tax, Probate

Denver IRS Practitioner Meeting July 2014 – A Summary Review with Excellent References for FBAR and FinCEN Matters

Meeting Summary as produced by IRS Senior Stakeholder Liaison Deborah Rodgers Nancy Carver, IRS Local Area Counsel Counsel continues to assist in training employees on partnership audits, and TEFRA. Counsel is also assisting in the investigations of promoters. Virtual currency

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Posted in IRS Appeal, IRS Audit, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, IRS Penalties, ITIN, Tax Abuse, Tax Guidance & Preparation, Tax Problems & Requests, Tax Refund

Use IRS Form 8082 to Report An Incorrectly Issued K1

I've been working a very complicated file since my last post involving income in 11 states and countless K-1s, Partner's Share of Income, Deductions, Credits, etc. Interestingly enough one of my trusted lieutenants noticed that one of the K-1s from one

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Posted in 1231 Exchange, Asset Classification, Audit Reconsideration, Business Income, Capital Loss, Distributions, IRS Appeal, IRS Audit, IRS Collections, IRS Enforcement, K1, Partnership, Passive Activity, Sub-chapter S, Tax Guidance & Preparation, Tax Problems & Requests, Uncertain Tax Position

A Brief Introspection of Repair vs. Improvement: IRS Revenue Procedures 2014-16 and 2014-17

That's right Y'all this is another one of those quite game changers for owners of tangible property concerned about keeping the IRS at bay by actually adhering to the specific US Tax Code and subsequent IRS Revenue Procedures. My apologies for

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Posted in 1031 Exchange, Business Expense, Depreciation, Rental Real Estate, Sole Proprietor, Tax Abuse, Tax Guidance & Preparation, Tax Problems & Requests

US v. Clarke SCOTUS Decision Favors Taxpayers

The SCOTUS clarified the 11th Circuit Court of Appeals in the United States v. Clarke Et. Al. that… “a taxpayer has a right to conduct an examination of IRS Officials regarding their reasons for issuing a summons when (s)he points to specific facts or circumstances plausibly

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Posted in IRS Audit, IRS Collections, IRS Enforcement, IRS Examination, IRS Penalties, IRS Penalty and Interest Abatement, Tax Abuse, Tax Court, Tax Deductible Expenses, Tax Guidance & Preparation, Tax Problems & Requests, Tax Relief

US v. Clarke SCOTUS Decision Favors Taxpayers

The SCOTUS clarified the 11th Circuit Court of Appeals in the United States v. Clarke Et. Al. that... "a taxpayer has a right to conduct an examination of IRS Officials regarding their reasons for issuing a summons when (s)he points to specific facts or circumstances plausibly

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Posted in Audit Reconsideration, Business Expense, IRS Enforcement, IRS Examination, Tax Abuse, Tax Court, Tax Deductible Expenses, Tax Guidance & Preparation, Tax Preparer, Tax Problems & Requests, Tax Relief
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