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Are You a US Citizen Living Outside the US Contemplating Expatriation (or not) – File An Extension Request Today?

The Perturbing New Treatment of Patents Under the Tax Cut & Jobs Act (TCJA)

Seeking Clarity in the US Tax Code on behalf of US Taxpayers Everywhere

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Posted in International Tax, Uncategorized

IRA ROLLOVER OF RETIREMENT PLANS SELF CERTIFICATION FOR MORE TIME

The Perturbing New Treatment of Patents Under the Tax Cut & Jobs Act (TCJA)

Normally you have 60 days to do an IRA rollover of retirement plan distributions in order to avoid current taxation and possible penalty. If you have special circumstances challenging your ability to complete the rollover within this 60-day time frame, please

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Posted in Uncategorized

Colorado Year End Tax Update: Focus on USE TAX – 50 Points of Light

The Perturbing New Treatment of Patents Under the Tax Cut & Jobs Act (TCJA)

Colorado Year End Tax Update: Focus on USE TAX - 50 Points of Light It is that time of year again where we work ourselves into a tizzy finishing off the year "strong" and simultaneously enduring another holiday season whilst

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Posted in Colorado Department of Revenue, Colorado Income Tax, Sales Tax, Uncategorized, Use Tax

LLC Income is INDEED Subject to Self Employment Tax: IRS Chief Counsel Advice 201436049

In 1997, the IRS issued proposed regulations governing when the distributive share of partnership income for Limited Liability Company (LLC) members was to be included in self-employment income. It basically advised that an LLC member would be treated as a

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Posted in Employment Tax, Entity Classification, Limited Partnership, LLC, Material Participation, Passive Activity, Payroll Tax Problems, Small Business, Social Security Tax, Taxable Income, Uncategorized

Top 8 Free US Tax Research Sites

The best free US tax research sites in my opinion are: 1. For actually referencing the US Tax Code - Cornell University Law School as they seem to do the best job with updates and maintenance and at the end

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Posted in IRS Appeal, IRS Audit, IRS Centralized Insolvency, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, IRS Levy, IRS Lien, IRS Mediation, IRS Penalties, IRS Penalty and Interest Abatement, IRS Transcript, ITIN, Tax Abuse, Tax Court, Tax Guidance & Preparation, Tax Problems & Requests, Tax Relief, Uncategorized, Uncertain Tax Position, United States Treasury

Tax Audit Musings

If you chose to represent yourself in an IRS Examination realize the IRS Revenue Agent (RA) or Tax Compliance Officer (TCO) assigned your file is trained very thoroughly to advocate on behalf of the US Government. One method used quite often

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Posted in Appeals & Audit Resolution, Audit Reconsideration, Audit Technique Guide, IRS Appeal, IRS Audit, IRS Collections, IRS Criminal Enforcement, IRS Enforcement, IRS Examination, IRS Levy, IRS Lien, IRS Mediation, IRS Penalties, IRS Penalty and Interest Abatement, Uncategorized

Situations that would not qualify for IRS Fast Track Mediation

Issues for which there is no legal precedent Issues where the courts have rendered opposing or differing decisions in different jurisdictions Industry Specialization Program issues An issue for which you filed a request for competent authority assistance Service Center penalty appeals cases Service Center Offer in Compromise cases Collection

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Posted in IRS Appeal, IRS Audit, IRS Collections, IRS Examination, IRS Mediation, Uncategorized

IRS Fast Track Mediation: Small Businesses + Self Employed

The IRS released Announcement 2011-05 creating opportunity for small business and self-employed taxpayers to use the Fast Track Settlement process to resolve disputes within the IRS's Small Business/Self Employed (SB/SE) units of the IRS in certain locations including Chicago, Ill.; Houston,

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Posted in IRS Mediation, Uncategorized

2011 Payroll Tax Instruction – IRS Notice 1036

According to the IRS millions of workers will see their take-home pay rise during 2011 because the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 provides a two percentage point payroll tax cut for employees, reducing their Social

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Posted in Employment Tax, Payroll Tax Problems, Uncategorized

IRS Examination Letters Offering an Appeal

Letter 525 – General 30 Day Letter This letter accompanies a report giving you a computation of the proposed adjustments to your tax return. It informs you of the courses of action to take if you do not agree with

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Posted in IRS Appeal, Uncategorized
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