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

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Posted in Alien, Alimony, Distributions, Expatriation, Foreign Income, Foreign Investment, International Tax, Paying Taxes

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

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Posted in Entertainment, Immigrant, IRS Audit Technique Guide for the Entertainment Industry, IRS Examination, Tax Relief

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

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Posted in Asset Classification, Auto, Business Expense, Car expense, Depreciation, Passenger Vehicle

Disability portion of SSA benefits (SSDI) will be removed from the FPLP 15% Levy for Past Due Tax Assessments

This is really confusing 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

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Posted in Disability, IRS Enforcement, IRS Levy, Social Security, SSI

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
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