Using IRS Form 843 for Abatements
The IRS regularly tacks on penalties wherever they can. Did [...]
Debt Cancellation Tax Consequences
Financially distressed borrowers may have some or all of their [...]
Partnership Special Allocations
One of the advantages of operating a business as a [...]
Change In Ownership Exclusions
Change of ownership exclusions. Change of ownership does not include: [...]
Other In Bound Rules
I will elaborate on the following four areas: Capital Gains [...]
Partnership audit procedures may affect your Partnership or LLC
How the partnership audit procedures may affect your partnershipThere are [...]
Decision Tree
Decision Tree 1: Inbound TransactionsAnalysis for Foreign Persons or Foreign [...]
Common Errors That Can Waive the Practitioner/Taxpayer Confidentiality Privilege
Common Errors That Can Waive the Practitioner/Taxpayer Confidentiality Privilege1. Including [...]
Gift Taxes-Introduction
When does the Gift Tax Apply? A gift tax is [...]
Branch Profits and FIRPTA
Branch Profits Tax and FIRPTA Where we are to date: [...]