With the holiday season officially upon us, the Dollars and Sense team wants to make sure you maximize your giving and gifting! For so many businesses, and business owners, this time of year also means employer festivities, and gifting, are about to be in full swing.

For business relationships, there is a tax upside: customer

In a bench opinion dated September 27, 2024, the Tax Court sustained a Notice of Federal Tax Lien but not the proposed levy against Daugerdas, a convicted tax shelter promoter in home confinement in Illinois.

The petitioner’s underlying tax liability came about from court-ordered criminal restitution as part of the conviction result, after the Department

The IRS has announced a significant shift in its approach to penalties for late-filed Forms 3520 and 3520-A, particularly concerning foreign gift and inheritance reporting. Effective immediately, the IRS will no longer automatically assess penalties for foreign gifts and inheritances reported on Form 3520 and will start reviewing reasonable cause statements for late-filed Forms 3520

In recent years, the government has continued to ramp up its investigatory efforts concerning trust arrangements that it deems abusive for tax purposes. These investigations have included so-called “section 643(b) trusts” and other trust schemes that lack economic substance. In many instances, these probes have resulted in criminal indictments against the promoters of

U.S. persons who make outbound investments in foreign corporations often have thorny federal reporting obligations. In addition to the commonly filed IRS Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations, these taxpayers may have separate requirements to file an IRS Form 926, Return of a U.S. Transferor of Property

In one of my favorite legal movies, A Few Good Men, the lack of evidence on a particular point is brought up when Demi Moore’s character says to Tom Cruise’s character that he knows that something is true. Tom Cruise’s character then exclaims “it doesn’t matter what I believe, it only matters what I can

Disagreements happen.  In the corporate context, one or more shareholders may share a different vision for the company than the other shareholders.  Or, there may be acrimony amongst the shareholders for other reasons, as can often happen with family-run businesses.  Regardless of the reason, sometimes shareholders simply want out. 

Fortunately, the corporate income tax laws