Conservation and preservation easements offer taxpayers some of the largest charitable contribution deductions to be had under the U.S. tax code, which is extraordinary when one considers that no property actually changes hands under such an agreement. Rather, the owner of the land, building, or art collection in question maintains his or her ownership but Read more about How Conservation and Preservation Easements Offer Huge Tax Benefits[…]

In a recent article on Deducting S Corporation Losses in Excess of Basis, I explained that the Large Business and International (LB&I) division of the IRS signaled a shift in enforcement tactics with its 2017 announcement of 13 issue-specific “compliance campaigns.” Eleven additional campaigns were launched in November 2017, suggesting that the initial 13 are Read more about The LB&I OVDP Declines and Withdrawals Campaign: An IRS Enforcement Initiative With Known Targets[…]

As I described in a previous post on Deducting S Corporation Losses in Excess of Basis, the IRS announced a shift in 2017 toward issue-specific enforcement practices for its Large Business and International (LB&I) division, built around 13 initial “compliance campaigns.” One of those campaigns centers on Form 1120-F, which many foreign business entities conducting Read more about Filing Your IRS Form 1120-F: Announcing Yourself Is Better Than Disqualifying Yourself[…]

In February of 2017, the IRS announced a major shift in enforcement methods for its Large Business and International (LB&I) division, with the revamped approach centering on issue-specific “campaigns.” The initial 13 campaigns are already underway. In past years, the enforcement activities of the LB&I have predominantly consisted of audits of the largest corporations, with Read more about Deducting S Corporation Losses in Excess of Basis[…]

You have likely heard stories about people settling their tax debts for far less than they owe. Is the IRS really in the business of wheeling and dealing with taxpayers? The answer is of course no, and as in all tax matters, no one should ever approach a tax problem with a mindset of outsmarting Read more about Make Me an Offer: What Is an Offer In Compromise?[…]

Over two-thirds of the tax revenues collected by the IRS come from deductions from employee paychecks—withheld income tax and FICA taxes. (FICA stands for Federal Insurance Contributions Act, the principal funding source for Social Security and Medicare). These taxes are sometimes referred to collectively as Employment Taxes, or Payroll Taxes. Given their vital importance to Read more about Trust Matters: Employment Taxes, Payroll Taxes Are Serious Business[…]

When the IRS determines that a taxpayer has failed to meet their obligations for paying tax and filing returns, the taxpayer may be required to pay an IRS tax penalty in addition to taxes owed and interest fees. The dollar amounts of such penalties vary, but all IRS penalties are meant to be severe enough Read more about IRS Penalties and Tax Penalty Abatement[…]

If you purchase a yacht or jet that will be used for the conduct of your business ventures, the acquisition should of course be structured so that the ownership of the vehicle clearly falls to your company, not to you personally. Most often, the appropriate business structure is a Limited Liability Company (LLC), which offers Read more about Sea Shells: Pros and Cons of Starting an LLC for Yacht, Jet, Golf Cart, or Other Vehicle Ownership[…]

Creative artists earn their income by tapping into a variety of revenue streams through licensing and royalty agreements. In the digital age, however, licensing of artistic works is a dispersed and complicated business, characterized primarily by a high volume of low-revenue transactions. Tracking the money owed to individual songwriters and musicians is no mean trick, Read more about Money Trapped: Miscalculations of Royalty and Licensing Income Resulting in Significant Underpayment to Creative Artists[…]

A person would need the stoniest of hearts to gaze upon Michelangelo’s Sistine Chapel or Picasso’s Guérnica and think about money. We all understand that the true value of a masterpiece cannot be expressed in either words or numbers—no one can put a price on art, the saying goes. Yet when tax time rolls around, Read more about Valuing Artwork for Estate Tax, Gift Tax, and Charitable Deduction Purposes[…]