THE PROBLEM OF INTERNATIONAL DOUBLE TAXATION
U.S. citizens and residents are taxed on their income from all sources worldwide. Worldwide taxation by the U.S. does not disarm the taxing power of other countries. Americans pursuing income outside of the U.S. are bound to encounter tax collectors asserting their own national claims. The world is awash in possibilities of double taxation. Check […]
Trust Fund Recovery Penalties: Much ado about something
The income and social security taxes an employer withholds from the wages of employees are called “trust fund” taxes because they are constructively held in trust for the government. All too often, when business owners encounter financial trouble, they fail to pay these taxes – not because of any plan to steal the money from […]
The Notice of Deficiency – Your ticket into Tax Court
The United States Tax Court has jurisdiction of federal tax issues. One of the most common cases over which the United States Tax Court has jurisdiction is tax deficiencies. A deficiency is an amount of tax that the taxpayer allegedly owes the IRS in excess of any amounts reported on the return. The notice of […]
Selecting the Appropriate Venue to Litigate a Tax Case
Tax cases can be heard in several different venues: United States Tax Court, United States District Court, United States Bankruptcy Court, or United States Court of Federal Claims. The rules applicable to each venue vary. Therefore, the selection of one court over another depends on the facts unique to each taxpayer’s claim. Tax Court is […]
Anatomy of a Federal Tax Controversy
Step one: The IRS conducts a tax audit. A tax audit is an examination of your income and expenses to ensure that you correctly reported your tax liability. All types of tax returns are subject to audit, including income, business, estate, and gift tax returns. Step two: The 30-day letter If a revenue agent determines […]
Definitions of commonly used tax terms
Deficiency: A taxpayer’s correct liability, as determined by the IRS, less the amount reported on the return. Assessment: In order for the IRS to use administrative procedures to collect the tax owed, it must first “assess” it. Assessment means formally recording the tax liability. Statute of limitations Collection: In theory, the IRS has only ten […]