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Tax Matters Related to the Transfer of Property Through Divorce

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When a 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 […]

IRS Offer in Compromise Resource Page

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Table of Contents1 What is an IRS Offer in Compromise?1.1 Offer In Compromise Pre Qualifier Tool1.2 IRS Offer in Compromise Form1.3 Where To Submit Your IRS Offer in Compromise1.4 What Decisions can the IRS make regarding my Offer?1.5 What Information is Public?1.6 Publication 594 The article below has been prepared to act as an IRS […]

Initial Considerations Regarding a Corporate Acquisition

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In any corporate acquisition, there are tax and non-tax issues, multiple business considerations, and the 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, […]

Employee Stock Options

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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 […]

Direct Stock Acquisition and Reverse Triangular Merger

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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 […]

Constructive Ownership Within Foreign Corporations

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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 […]

Streamlined OVDP by Denver Tax Attorney

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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 […]