United States Tax Court Agrees with Taxpayer and Finds Reasonable Cause to...
This post was co-authored by Adam Landy and Erik Doerring. On July 5, 2011, the United States Tax Court abated penalties assessed by the IRS against a business taxpayer for failure to pay its...
View ArticleIRS Reverses Position On Equitable Innocent Spouse Relief Claims
On July 25, 2011, the Internal Revenue Service issued IRS Notice 2011-170, 2011-32 I.R.B. 135 and announced that it will help taxpayers who request innocent spouse relief by eliminating the two-year...
View ArticleTransferring Sales Tax Liability to Purchasers in South Carolina
South Carolina imposes various taxes and reporting requirements on purchasers transacting business in the state. A sales tax is imposed on the sale at retail of tangible personal property and certain...
View ArticleThe IRS Offer in Compromise: A Way to Resolve Outstanding Federal Tax...
Generally, there are four methods of resolving an assessed federal tax liability: (1) full payment, (2) payment through installments under a written agreement, (3) an offer in compromise, and (4)...
View ArticleThe Joy of Reporting Income Earned in Foreign Countries to the IRS
U.S. citizens that work or receive income from abroad are subject to U.S. income taxes on foreign income. The tax is applicable regardless of where U.S. citizens reside. U.S. taxpayers receiving...
View ArticleReinstatement for Tax-Exempt Organizations whose Exemption Status was...
Many individuals and business entities create charitable organizations to serve the needs of a specific group of persons or a specific community with a need for a type of service. Most charitable...
View ArticleIRS Revises Streamlined Installment Agreement Program
There are five general methods of resolving an assessed federal tax liability: (1) full payment, (2) payment through installments under a written agreement, (3) placing an account into currently...
View ArticleIRS Announces More Flexible Offer-in-Compromise Terms to Help More Struggling...
On Monday, May 21, 2012, the Internal Revenue Service announced another expansion of its “Fresh Start” initiative by offering more flexible terms to its Offer in Compromise (“OIC”) program with the...
View ArticleThe Importance of a Qualified Appraisal for Conservation Easements
Landowners may be allowed a federal income tax deduction for the contribution of a conservation easement restricting donated property. A qualified conservation contribution is a donation of a...
View ArticleIRS Announces New Procedures for U.S. Citizens Residing Overseas Who Have Not...
The IRS has long been aware of U.S. taxpayers living overseas who have not filed federal income tax returns or Reports of Foreign Bank and Financial Accounts (“FBARs”). Earlier this year, the IRS...
View ArticleSouth Carolina Supreme Court Rejects Challenge to Sales and Use Tax...
On Wednesday, May 8, 2013, the South Carolina Supreme Court (the “Court”) rejected a taxpayer’s constitutional challenge to the state’s sales and use tax caps and exemptions codified in South Carolina...
View ArticleThe Internal Revenue Service Acquiesces to Broad Standard of Review in...
The Internal Revenue Service (“IRS”) has acquiesced in the U.S. Court of Appeals for the Ninth Circuit’s decision in Wilson v. Commissioner, 705 F.3d 980 (9th Cir. 2013), aff’g, Wilson v. Commissioner,...
View ArticleInternal Revenue Service Updates Procedures for Organizations Requesting...
On January 2, 2014, the Internal Revenue Service (the “IRS”) issued an advance copy of Revenue Procedure 2014-11 which updates the procedures for an organization to request retroactive or...
View ArticleIRS Makes Substantial Changes To Foreign Bank Account Offshore Voluntary...
On June 18, 2014, IRS Commissioner John Koskinen announced important modifications to the IRS 2012 Offshore Voluntary Disclosure Program (OVDP), including the expansion of the favorable Streamlined...
View ArticleSame-Sex Marriages In South Carolina: Tax Implications of Condon V. Haley
In Colleen Therese Condon and Ann Nichols Bleckley v. Nimrata (Nikki) Randhawa Haley, et al., Civil Action No. 2:14-4010-RMG (November 12, 2014), the United States District Court for the District of...
View ArticleSame Sex Couples May Now File Married Income Tax Returns in South Carolina
Robert is a veteran tax return preparer of 20 years, who walks into his office on February 2, 2015 to begin a busy income tax filing season. Julie and Michelle stop by Robert’s office and give their...
View ArticleSouth Carolina Department of Revenue Issues Guidance Regarding the Tax...
On December 2, 2014, the South Carolina Department of Revenue issued S.C. Temporary Revenue Ruling No. 14-8 and No. 14-9 regarding the income and property tax treatment for married same-sex couples....
View ArticleForget to File Your FBAR? Don’t Worry, You Can Still File Without Incurring...
The U.S. Treasury Department has issued much-awaited guidance for U.S. citizens and permanent residents who have foreign bank accounts and who have not filed their required U.S. bank account reports....
View ArticleSouth Carolina Economic Development Incentives: Jobs Tax Credit
South Carolina offers a statutory incentive to new and expanding businesses that create jobs in our state. The Job Tax Credit (“JTC”), codified in S.C. Code Ann. § 12-6-3360, permits certain businesses...
View ArticleThe Revocable Trust: Is This a Necessary Component of Your Estate Plan? (Part 2)
Is a revocable trust for you? There are a number of factors for you and your attorney to consider. One considerations is the most efficient and cost-effective way to transfer assets at death to your...
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