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Yearly Archives: 2012

Willfulness in trust fund penalty must be determined at trial

In a summary judgement, a district court has concluded that a taxpayer who was vice-president, board member, and shareholder of his family-run company was a responsible person for purposes of the Code Sec. 6672 trust fund recovery penalty. However, the district court found that whether the taxpayer, who played a perfunctory role in his company,…
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Tax Fraud Against Preparers Affirmed by the Fifth Circuit

The convictions of a couple that committed tax fraud were affirmed by the Fifth Circuit Court of Appeals. The husband and wife were the owners and operators of a firm that prepared personal income tax returns in Texas. A husband and wife were indicted for offenses arising out of their business of preparing federal income…
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Ecuador Declares “US LLCs” as a Preferential Tax Regime – Tax Haven!

                   Preferential tax regimes are jurisdictions where income is subject to tax at a rate 60% lower than in Ecuador (Ecuador current corporate income tax is 23%). US LLCs have been declared to be a preferential tax regime if owned by US non resident aliens and if income is not subject to federal income tax…
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