IRS Offshore Compliance Options for Foreign Asset Reporting Many tax practitioners and taxpayers have noticed increased enforcement in the international tax space. It’s always better to correct failures in filing foreign information returns or FBARs before receiving a letter from the IRS. In certain situations, taxpayers who are living in the Unite...
What Is a Trust Fund Recovery Penalty and How the IRS Enforces It A Trust Fund Recovery Penalty (TFRP) is one of the most serious payroll tax enforcement actions the IRS can impose. When employment taxes are not properly remitted, the IRS may assess personal liability against individuals deemed responsible for collecting and paying those taxes. Unl...
What Is the Section 121 Principal Residence Gain Exclusion? When a taxpayer sells a principal residence, the Internal Revenue Code allows eligible homeowners to exclude a portion of the gain from taxable income under Section 121. Individuals may exclude up to $250,000 of gain, while married couples filing jointly may exclude up to $500,000 if they ...
Why Tax Issues Matter in Divorce Tax issues are frequently overlooked in divorce litigation. Parties often focus on custody disputes and dividing assets, but the tax consequences of those decisions can dramatically alter the true economic outcome of the divorce. This article discusses three very important tax issues that arise in a divorce case and...
December Case Result - 1 Richard James of The Wilson Firm represented a commercial real estate investor in the purchase of two commercial properties used by a major equipment company in a deal that qualifies under income tax law as sale-leaseback transaction. Total transaction value was in excess of $10 million.
Tax Court settlement saves taxpayer $170,409 (plus interest)! The IRS issued a Notice of Deficiency asserting that the taxpayer failed to report the sale of two rental properties and proposed increasing taxable income by $555,000 as ordinary income, resulting in an additional tax assessment of $190,737.19, plus failure-to-file and substantial tax u...
Significant Relief for Taxpayers Reporting Foreign Gifts and Inheritances At the urging of the Taxpayer Advocate Service and practitioners, the IRS has ended its practice of automatically assessing penalties at the time of filing for late-filed Forms 3520 to report foreign gifts and inheritances. Also, by the end of the year, the IRS will begin rev...
How We Secured a $1.1 Million Property Tax Reduction for Our Client The Wilson Firm recently achieved a significant victory for its client, a subsidiary of a Fortune 100 company. The case involved a dispute with Montgomery Central Appraisal District over the value of approximately 30 acres of commercial property located in The Woodlands, Texas. The...
How We Helped Reduce Offshore Tax Penalties by 87% Client worked for an international oil and gas company based in Europe, where the employees had the equivalent of a European 401k. The client was given erroneous advice and never reported this foreign account when filing their tax returns. Before coming to The Wilson Firm, the client was looking at...
Case 1 A business hired us to assist with a sales tax audit with the Texas Comptroller. We were able to lower the liability by around $87k by providing additional arguments and supporting documents to the auditor. Additionally, we were able to secure a penalty waiver in the amount of 20k.
Case 2 The client hired us to assist with a sales tax audit. We were able to secure a fraud penalty reduction in the amount of 134k after submitting a legal argument in favor of removal of the penalty with a Request for a Redetermination.
Successfully Lifted IRS Bank Levy on Individual's Wages. Our firm represented an individualwith about $165,000 in outstanding federal income tax liabilities (Form 1040), includingpenalties and interest. After the IRS issued a wage levy, nearly 70% of the client's wages werebeing garnished by the IRS. We intervened promptly and negotiated a release ...
Successfully Lifted IRS Bank Levy for Religious Organization Client. Our firm represented areligious organization with more than $310,000 in outstanding federal payroll tax liabilities(Form 941), including penalties and interest. After the IRS issued a bank levy, the client facedan immediate inability to meet payroll and pay essential operating exp...
Successfully Defended NRP Audit Client owned six businesses, including several auto shops and an ambulance dealership. Client was randomly audited for the 2021 tax year under the National Research Program. NRP audits are random audits solely made for the IRS benefit, to: (1) "enable the IRS to gather strategic information about taxpayer compliance ...
Successfully Lifted IRS Bank Levy for Corporate Client Our firm represented a corporate taxpayer with more than $550,000 in outstanding federal payroll tax liabilities (Form 941), including penalties and interest. After the IRS issued a bank levy, the client faced an immediate inability to meet payroll and pay essential operating expenses. We inter...
Represented Buyer in Purchase of Two Equipment Rental Locations Through Sale-Leaseback Represented a high-net-worth real estate investor in the purchase of two equipment rental locations via a sale-leaseback transaction. Our team advised on the acquisition structure, tax implications, and long-term investment strategy to support stable returns and ...
Successfully negotiated with the Department of Justice on behalf of a client who owned multiple offshore companies and bank accounts to DECLINE criminal prosecution for willfully failing to file Foreign Bank Account Reports ("FBAR") for 9 years, as well as reducing the civil willful FBAR penalties by 69% from the statutory maximums that applied in ...
Facilitated Nearly $2.3 Million IRS Refund The taxpayer filed a claim for refund caused by carrying back substantial 2020 losses to 2015 under the CARES Act (part of the Covid relief), which allowed taxpayers to carry back net operating losses (NOL) for 2018 through 2020, for up to five years. A year passed after the taxpayer filed his tax refund c...
Represented Buyer in $6M Multistate Logistics Company Acquisition Richard represented the buyer of a $6 million logistics company with operations in multiple states. Our work included advising on the purchase agreement, assisting with financing, navigating income tax considerations, structuring purchase price allocation, and coordinating a Section ...
Advised on Trust Domestication & Ending California Tax Nexus Richard advises a second-generation high-net-worth client on domestication of trusts and the closure of California entities in order to eliminate California tax nexus on investment income. This restructuring significantly improved the client's long-term tax posture while maintaining a...
