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Tax Articles

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 introspective artists in San Francisco to international bankers in Moscow, coffee plantation owners in El…


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 daily struggle to create new jobs. However as a person who prepares, signs and files…


Foreign Investment in Real Property Tax Act and Your TIN – IRC 897, 1445; TD 9082; IRS Form 8882, W-7

As part of an IRS Examination under the Foreign Investment in Real Property Tax Act (FIRPTA) you absolutely must have a Taxpayer Identification Number (TIN) to mitigate 26 U.S. Code § 1445 – Withholding of tax on dispositions of United States real property interests If you do not qualify for a Social Security Number (SSN) you may…


Exceptions to the requirement that a U.S. Federal Income Tax Return Accompany an ITIN Application – IRS Form W-7

You can indeed claim an exception to the requirement to submit an original U.S. Federal income tax return with IRS Form W-7 – ITIN Application, all you need is substantiated proof of your claim. So what are the exceptions allowing for the ITIN application without a tax return and how do you substantiate your claim? Exception 1.…


What is an ITIN? T.D. 8671, 1996-1 C.B.314

In 1996, the U.S. Treasury Department issued T.D. 8671, 1996-1 C.B.314 introducing the ITIN – Individual Taxpayer Identification Number – requiring people foreign to the USA to use a unique identification number on their United States federal income tax returns. These regulations were intended to address concerns by the IRS and elected officials that without a unique…


Why to Revoke An S Election and How to Do It – Internal Revenue Code Section 1362(d); Reg § 1.1362­6(a)

Many entrepreneurs get caught up in selecting the “most appropriate business structure” – particularly people planning to conquer the moon right out of the gate. If this is you beware as business structure is a determination that is best driven out of operational efficacy. Why? Most all new businesses fail, it is a fact of life. Properly…