IRS Penalties for Late-Filed Forms 5471

The Dewees v. United States, 16-cv-01579 (D.D.C. 2017) case is a good reminder that late-filed Forms 5471 should include reasonable cause statements. These statements can be submitted under the IRS’s Delinquent International ...
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About Filing Tax Returns Late

Statistics show thаt you are likely tо mіѕѕ a tax return fіlіng deadline аt some роіnt іn your lіfе. It happens.  Life happens: wоrk, vасаtіоn, family circumstances, and even financial problems.  These ...
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Intercompany Receivable Results in Section 956 Inclusion for U.S. Corp.

The Subpart F rules can result in foreign profits being subject to tax in the U.S.  In the recent Crestek v. Commissioner, 49 T.C. 5 (2017), the court addresses unpaid advances a controlled foreign ...
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What You Should Know About the IRS Offer in Compromise Program

If you owe the IRS you may be surprised to find out that the IRS may settle the debt for less than the amount owed.  One way to do this is through ...
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Tax Court Says Royalties Paid to Roth IRA Were Excess Contributions to IRA

The U.S. Tax Court recently issued another opinion involving a LLC owned by a self-directed IRA. The case is Block Developers, LLC v. Commissioner, T.C. Memo. 2017-142. The case invovles an IRA ...
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Cash-Basis Taxpayers Can Deduct Reclamation Costs Under Sec. 468

Section 468 allows a current deduction for mining and solid waste reclmation costs even though the expenses may not be incurred for several years–if not decades–in the future. It has traditionally been ...
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The Form 1045 Dispute & Possible Solution: Include a Detailed Cover Letter

The Form 1045, Application for Tentative Refund, is used to carryback losses, credits, etc. from the current year to prior years. In many cases it is used when a taxpayer was previously ...
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Court Says No Tax Due on Foreign Corporation’s Redemption of U.S. Partnership Interest

Many businesses that operate outside of the U.S. want to do business in the U.S. and they want to limit their exposure to U.S. income taxes. To do this, many in-bound investments ...
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Have an IRS Dispute, What You Need to Know About IRS Appeals

If you have and IRS dispute brewing and you have not been able to resolve the matter with the IRS, you are probably going to have to ask the IRS Office of ...
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Settlement Award for Discrimination Related to Physical Injuries is Taxable

Damage awards received on account of personal physical injuries or physical sickness are not taxable. If a taxpayer receives a non-taxable award under this rule and then is discriminated against by his ...
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