On June 27, 2019 the Office of Management & Budget (OMB) reported on its website that it has finished its review of the Obama-era regulations that would significant changes to the minimum investment amount, as well as other consequential changes. The regulations have proposed increasing the minimum investment of $500,000 to $1.35 million, and the…
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How NOT To Handle an IRS Collection Matter
According to DoJ, Wagdy A. Guirguis, owner of several engineering businesses, was sentenced June 28, 2019 to 5 (five) years in prison in Honolulu. On Nov. 20, 2018, a jury convicted Guirguis of: Conspiracy to defraud the United States along with co-conspirator Michael Higa, Three counts of filing false corporate income tax returns, One…
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U.S. Citizen Resident in US Possession Was A Nonresident/Noncitizen For Estate, Gift, GST Purposes
A taxpayer who was born outside the U.S. and its possessions, whose parents were not U.S. citizens at the time of his birth, and who became a U.S. citizen after residing in a U.S. possession was a "nonresident not a citizen of the U.S." for estate, gift, and generation skipping transfer tax (GST) purposes. PLR…
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Minority Shareholder & President Libel For Trust Fund Recovery Penalty Minority Shareholder & President Liable for Trust Fund Recovery Penalty
A district court has found that the IRS properly determined that a corporation’s minority shareholder and president was liable for the trust fund recovery penalty under Code Sec. 6672. As president, the individual approved, signed, and submitted a variety of tax forms and documents to Federal and state authorities on behalf of the corporation. Therefore, he was…
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