Three Things – Ask A Tax Attorney

Recently, I wrote an article for the Hennepin County Lawyer addressing some of the kinds of tax questions that non-tax attorneys receive from their clients. The text of this article is included below: Tax touches almost everything. As a tax attorney, this keeps my job very interesting. This also means that even non-tax attorneys likely [...]

What To Do if I Can’t Pay My Taxes by the IRS’s July 15 Tax Deadline

            In light of the current Covid-19 pandemic, the Internal Revenue Service (IRS) extended the April 15, 2020, filing and payment deadlines for federal individual income taxes for the 2019 tax year to July 15, 2020. Due to the pandemic, many taxpayers are finding themselves in difficult financial circumstances. They are unable to pay their [...]

IRS Releases People First Initiative FAQs

On March 25, 2020, the Internal Revenue Service (IRS) announced its “People First Initiative,” a program intended to respond to the challenges of Covid-19 by providing a variety of relief related to IRS deadlines and collection actions. For additional information, please see our previous blog article regarding the People First Initiative here and the full [...]

IRS Response to Covid-19: “People First Initiative” Extends Certain Payment Deadlines and Collection Action

On March 25, 2020, the Internal Revenue Service (IRS) released guidance related to its “People First Initiative,” a program intended to respond to the challenges of Covid-19 by providing a variety of relief related to IRS deadlines and collection actions. The full IRS press release can be found here. As part of its People First [...]

How to Appeal the Trust Fund Recovery Penalty After the Appeal Period has Passed: Offer in Compromise, Doubt as to Liability

There are many reasons businesses fall behind on paying their federal tax liabilities. Falling behind on certain kinds of taxes, sometimes called “trust fund” taxes, may result in the IRS assessing those taxes against the business owners, officers, or other individuals the IRS considers to be “responsible” for ensuring the payment of those taxes.  Federal [...]

State Sales Tax and Corporate Income and Franchise Tax After Wayfair

On June 21, 2018, The United States Supreme Court ruled 5-4 in South Dakota v. Wayfair that states can mandate that businesses without a physical presence in a state but with more than 200 transactions in or $100,000 in in-state sales must collect and remit sales taxes on transactions in the state. In this article, [...]

IRS Taxpayer Roadmap

The Internal Revenue Service (IRS) Taxpayer Advocate Service (TAS) recently released the above “subway map” to illustrate, at a very high level, the stages of a taxpayer’s journey through the tax system. The map provides a high level overview of the processes for tax return preparation, tax return processing, notices from the IRS, audits, appeals, [...]

IRS Announces Increase to Late Filing Penalties for 2018 Federal Tax Returns

The IRS recently announced that taxpayers who owe tax and did not file their 2018 returns before Friday, June 14, 2019 will be subject to increased late filing penalties.  penalty kicks in. The failure-to-file penalty is assessed if there is unpaid tax and the taxpayer fails to file a tax return or request an extension [...]

IRS Ramps Up Scrutiny of Foreign Trusts

[vc_row][vc_column][vc_column_text] Taxpayers often wonder how they might be selected for audit by the Internal Revenue Service (IRS). Often, audit selection is random. However, the IRS also runs certain “compliance campaigns” related to areas in which the IRS detects a significant increase in abuse by taxpayers or their advisors. Changes in bank secrecy laws of foreign [...]

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