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When property is transferred because of a divorce, is the transfer of property taxable and what tax issues should be considered?  This is a common question when an individual is going through a divorce and begins to look at and consider the settlement agreement and terms the parties are discussing.  The article and information below...
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Can the Internal Revenue Service refile a Notice of Federal Tax Lien?  This is a very important question if in fact the IRS has filed a tax lien on you or your business.  The answer, of which, greater detail is provided below, is yes, the IRS can refile a tax lien.  The article below has...
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Can I plead the 5th during the course of my communications with the Internal Revenue Service?  This a common question I am asked by clients and taxpayers who may be under an IRS audit, IRS debt matter or other related tax issue.  The article below has been prepared to provide general information regarding this matter,...
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The article below has been prepared to act as an IRS Offer in Compromise resource page whereby individuals can obtain necessary information regarding an IRS Offer in Compromise.  Please note, this information is not legal advice and should not supplement the advice of a tax attorney or tax professional. What is an IRS Offer in...
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In any corporate acquisition, there are tax and non-tax issues, multiple business considerations and goals of the parties involved with the transaction.  The tax planning that is involved before, during and after the acquisition process may include many options and alternatives to achieve the tax and non-tax wishes and goals of the parties.  Thus, one...
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Successful businesses will have successful, driven and strong employees.  Often businesses are faced with questions and issues regarding maintaining employees, hiring the right employees and incentivizing employees.  Incentive compensation arrangements are often used by large and small businesses as a means by which to reward employees, as well as a benefit to individuals the business...
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There are multiple options to implement the acquisition of a business.  The purchaser or acquirer could purchase the stock of the target corporation, or the assets of the target corporation.  If the stock of the target corporation is to be purchased there are multiple options and variations by which the stock can be acquired.  The...
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Under the context of controlled foreign corporations, a U.S. shareholder is defined as a U.S. Person who owns or is considered as owning 10% or more of the total combined voting power of all classes of stock entitled to vote of a foreign corporation.  Does this language mean that constructive ownership is considered when determining...
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What is the Streamlined Offshore Voluntary Disclosure Program (OVDP)?  Simply put, the Streamlined OVDP is a program established by the IRS that may be considered “shortened” or “simpler” than the normal OVDP, and has a reduced or lesser penalty of 5% in comparison to the OVDP.  Certain criteria must be met to be eligible for...
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If you have claimed a filing status of Head of Household, the IRS may ask you to verify the elements that allow you to claim head of household.  The IRS can send you written notice requesting documents and information that would verify your status.  Form 886 H HOH helps provide the requirements of claiming head...
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