The wages of a permanent resident of the United States that were paid by Germany and a foreign government office were not exempt from taxation under the tax code and a North Atlantic Treaty agreement, the U.S. Tax Court held May 1 (Harrison v.Commissioner, T.C., No. 15074-10, 138 T.C. No. 17, 5/1/12). The Tax Court…
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Philip Marris Agrees to Pay $500MM to Resolve LILO and SILO Leasing Transactions
RICHMOND, VA – May 22, 2012 – Altria Group, Inc. (Altria) (NYSE: MO) today announced that it has executed a Closing Agreement (Agreement) with the Internal Revenue Service (IRS) that, subject to court approval, resolves the federal income tax treatment for all prior tax years of certain leveraged lease transactions (referred to by the IRS…
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“Pennies on the Dollar” – IRS Expands Offers in Compromise!
The IRS has completely revamped its offer in compromise guidelines to greatly increase the number of taxpayers who will be able to qualify. The new guidelines are announced in a news release by the IRS (IR-2012-53, May 21,2012). Our tax attorneys will be revisiting many of the offers in compromise that are pending, and we…
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Use of Offshore Insurance Scams & Merchant Accounts to Evade Taxes – IRS Zeroing in on.
According to senior government officials, the government is continuing to crack down on offshore tax avoidance in a variety of ways, including a new focus on the use of offshore insurance companies and offshore merchant accounts to hide assets. Officials described many facets of an overall goal to stopping tax evasion, speaking to the Civil…
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