2015 Meal and Incidental Expense Per Diem Rates

Many of you travel quite extensively for work and actually enjoy it, bless your heart. That life presently is not for me. With a young family to raise being home at night is HUGE. Perhaps one day though as the

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Posted in 2015-63, Business Expense, Meal Expense, Per Diem

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

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Posted in Business Expense, Marijuana, Tax Court, Tax Deductible Expenses, Tax Guidance & Preparation

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

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Posted in Foreign Income, Foreign Investment, International Tax, Tax Treaties

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

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Posted in Foreign Income, Foreign Investment, International Tax, IRS Examination, Tax Abuse, Tax Court, Transfer pricing

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

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Posted in China, Competent Authority, International Tax, Israel, Tax Treaties

General ITIN References & Contact Information Including IRS Pub 1915 & IRS Rev Proc 2006-10

Aside from this tax blog the following are the most useful resources for researching Individual Taxpayer Identification Number (ITIN) application processing. IRS Publication 1915 General ITIN Information page Update to the Instructions for Form W-7 and ITIN Processing Time IRS

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Posted in International Tax, ITIN

Do You Need an Individual Taxpayer Identification Number (ITIN)?

If you do not have a Social Security Number (SSN) and are not eligible to obtain a SSN, but you are required to provide a tax identification number (TIN) to file a U.S. Federal income tax return, be claimed as

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Posted in Alien, ITIN

Yes! Undocumented Aliens Can Qualify for an Individual Taxpayer Identification Number (ITIN) from the IRS

I personally believe that it is in EVERYONE'S best interest for all people materially present in the USA to be here LEGALLY. I also believe that the US Federal government has an obligation to do a much better job of

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Posted in Alien, ITIN

Brian Dooley’s Tax Research Tool

I was reminded late last night while knee deep in yet another complex file that one of my many blessings has been the opportunity to connect on several distinct levels with many different people all over this great planet. From

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Posted in Tax Research

IRS Proposes Elimination of Automatic Filing Extensions for W-2 Forms

I tend to harbor deep resentment whenever the IRS proposes more restrictions on job creating taxpayers. After all WE are the backbone of the US economy and our government agencies absolutely must focus on mitigating obstacles for hard working entrepreneurs in their

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Posted in Employment Tax, FICA, Payroll Tax Problems, Small Business, W-2
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