On Monday, March 11, 2013, we postedThe IRS Revokes Amnesty to US Taxpayers With Israeli Bank Accounts...They Must be Feeling Faclept;" where we discussed that the Internal Revenue Service sent faxes to tax attorneys nationwide informing them that clients who were previously accepted into its criminal amnesty program for those who disclose once-secret offshore accounts,…Read more
IRS EXPANDS AUTOMATED $10,000 PENALTY PROGRAM TO FORM 5472.
The IRS has begun applying automatic penalties to late-filed Form 5472's. We knew that since 2009 the IRS has automatically assessed a $10,000 penalty for late-filed Forms 5471's - Information Return of US Persons With Respect to Certain Foreign Corporations. However, we have been receiving a lot of calls from businesses who have recently received penalty…Read more
S Corporation Shareholder Compensation – How Much Is Reasonable?
A shareholder-employee’s compensation from an S corporation is often subject to IRS scrutiny because S corporation flow-through income enjoys an employment tax advantage over that of sole proprietorships, partnerships and LLCs. This advantage finds its genesis in Revenue Ruling 59-221, which held that a shareholder’s undistributed share of S corporation income is not treated as self-employment…Read more
When You Need a Tax Attorney not a tax resolution firm?
Reprint of Blog Post - AnthonyParent: This is a true story: In 2011, “Steve,” a taxpayer in New York City, is in serious trouble with the IRS. He searches the internet for an “IRS tax attorney.” He makes the mistake of believing a tax resolution firm in California are attorneys (because they claim to be).…Read more