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Non-Willful Conduct Under Streamlined Offshore Voluntary Disclosure Program

Non-willful conduct is required under the Streamlined Offshore Voluntary Disclosure Program (Streamlined OVDP).  If the failure to report foreign bank accounts and/or foreign financial assets was non-willful, you may be subject to a lower penalty base.  The key question is, what constitutes non-willful actions by a taxpayer?  Generally, the IRS would consider non-willful to mean […]

Common Capital Contributions to a Partnership

When forming a partnership the partners will make initial capital contributions and may make additional contributions depending upon the operations of the partnership and partnership agreement.  Common capital contributions may include cash, property (vehicles, equipment, computers etc.) and sometimes services. The video below has been prepared by a tax attorney and business attorney at The […]

When is a Collection Due Process Hearing Available?

A taxpayer has the right to a collection due process hearing with the Internal Revenue Service Appeals Office under certain circumstances.  This hearing can be very beneficial to a taxpayer in terms of preventing enforcement action such as a bank levy or wage garnishment and by a means to establish or propose an agreement with […]

Deducting Business Expenses

Can I deduct my meals as a business expense?  Can I deduct this flight as a business expense?  Can I deduct the cost of my clothes or uniform as a business expense? As a tax attorney, these are common questions I am asked, and rightfully so as everyone wants to take advantage of all potential […]

Attempting to Avoid Shareholder Loan Reclassification

Many corporate shareholders may have taken a loan from their corporation.  In a prior article, we discussed issues related to corporate loans and issues considered regarding the reclassification of a loan.  The article below discusses issues and actions a shareholder may consider taking to prevent the reclassification of a loan.  Please remember that this article […]