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IRS Letters and Notices Offering an Appeal Opportunity

There are many missed opportunities to solve tax problems with the IRS through the IRS Appeals office. Below is a list of the most common IRS letters and notices affording an IRS appeals opportunity. Letter 11 – Final Notice of

ABA Conference with Government Officials

The ABA recently held a conference titled National Institute on Criminal Tax Fraud and Institute on Tax Controversy.  I attended the conference where many tax attorneys and government officials discussed issues of interest. Also discussed was the effect of streamlined

Beware of FATCA Letters

FATCA letters (sometime called Self Certification letters) are going out from banks around the world to millions of US expats in readiness for reporting their financial information to the Internal Revenue Service (IRS). If you are one of the 8

IRS Most Common Tax Notices and What They Mean

The IRS has redesigned its correspondence notices to be more “user friendly.”  This is supposed to make their notices easier to understand and therefore allow responses to occur in a more effective and efficient manner.  IRS tax notices will now

US Taxation of Foreign trusts: Foreign grantor trust

What is a foreign grantor trust (“FGT”). A FGT is typically used when a non-U.S. Person individual (i.e., an individual who is a non-U.S. citizen, not a “green card” holder, or otherwise not considered a U.S. income tax resident) wishes

5 Estate Planning Tips to Avoid Disputes

Insert a no-contest clause When a will contest seems likely, an in terrorem clause may be beneficial. An in terrorem clause, also known as a “no-contest” clause, generally provides that a bequest will fail if the beneficiary initiates or participates

Action Required: New Jersey Estate Tax is Repealed

Earlier this month, on October 14, 2016, New Jersey Governor Chris Christie signed into law that increased the NJ Estate Tax exemption from $675,000 to $2 million for deaths in 2017, and fully eliminated the state estate tax in full

New Jersey to repeal estate tax

Last week, the New Jersey legislature announced its plan to repeal estate tax by January 2018.  The New Jersey estate tax is presently one of the highest in the nation. For state residents the estate tax exemption would be increased

Resolving IRS disputes through audit reconsideration

An audit reconsideration is defined by the Internal Revenue Manual (IRM) as: the process the IRS uses to reevaluate the results of a prior audit where additional tax was assessed and remains unpaid, or a tax credit was reversed. If the

Taxation of Employment-related Discrimination Claims

Proceeds from a settlement involving an employment-related discrimination case may be taxable to the employee under some circumstances and not taxable in others.   Non-taxable settlement amounts: Medical expenses associated with medical distress; Emotional distress, pain or suffering resulting from

Article Discusses Termination of Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Filing Compliance Procedures (SFCP)

The Internal Revenue Service (IRS) currently offers non-compliant US taxpayers several different relief programs in which to report foreign assets and/or income and become compliant with US rules related to the disclosure of foreign assets. One option is the Offshore

Income Taxation of FMLA Claims

The Family Medical Leave Act requires employers with 50 or more employees to grant 12 weeks of unpaid leave to an employee in the event of a birth, adoption or serious health condition — whether it’s the employee or someone

Happy Birthday Streamlined Filing Compliance Procedure!

The Streamlined Filing Compliance Procedure (SFCP) was “born” two years old.  Two years ago the IRS publicly announced the SFCP, which has been used by many non-compliant US taxpayers with the disclosure of foreign assets. SFCP has two sub-programs: one

How to Respond to an IRS CP3219N Notice of Deficiency (90-day letter)

Under Sec. 6212(a) the IRS can issue a statutory notice of deficiency, also known as a 90-day letter, when it determines a deficiency in an income or estate and gift tax liability. A 90-day letter is a formal legal notice,

New Trust Law Enacted in New Jersey

On January 19, 2016, the New Jersey Uniform Trust Code (NJUTC) was enacted into law.  The new law will take effect on July 17, 2016.  The new law, based in part on model legislation prepared by the Uniform Law Commission,

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