IRS Special Agents & Criminal Investigations The Internal Revenue Service performs criminal investigations into individuals suspected of tax evasion, money laundering, drug trafficking, and other crimes. These investigations are conducted primarily by special agents assigned to the Criminal Investigation Division (CID). However, several sources of criminal investigation data are used by CID investigators. A Denver...Read More

Can the IRS Take Your Passport? Congress passed legislation in January 2018 that defines people who owe more than $50,000 in federal income taxes as “seriously delinquent” and risk losing their passport. This classification triggers a process where the IRS sends out notices to taxpayers who are overdue on payments. If you ignore those notices,...Read More

What Is An Abusive Tax Scheme? You may have heard of a program or tax scheme that promises to eliminate or substantially lessen your tax burden and taxes due to the Internal Revenue Service. A promoter of such a scheme will likely use financial instruments such as a trust or pass-through entities such as a...Read More

What is the FBAR statute of limitations for penalty assessments? What other FBAR statutes should I be concerned about? If you have failed to file your FBAR, also known as FinCEN Form 114, you may ask yourself these questions. The article below was prepared by a Denver tax attorney at The McGuire Law Firm and will examine and...Read More

Limited Liability Companies Conflict With An S Corporation Operating Agreement Abiding by the LLC operating agreement may cause the entity to operate in a manner that invalidates the S corporation election.  An LLC can be formed quickly and has a lot of flexibility regarding members, operations, and taxation structure. It is not rare for an...Read More

For many individuals, the Streamlined Offshore Voluntary Disclosure Program provided welcome relief in comparison to the “initial” Offshore Voluntary Disclosure Program.  Many taxpayers with foreign accounts and assets contact wonder what forms and documents must be filed to apply for the Streamlined Offshore Voluntary Disclosure Program.  In general, taxpayer’s must file the necessary FBARs, amend...Read More

When an offer in compromise is submitted to the IRS, the IRS may agree that the taxpayer is an offer candidate, but not agree with the original offer in compromise amount.  Thus, can the initial offer in compromise be amended?  Yes, the offer can be amended to reflect a different amount and terms. This issue...Read More

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...Read More

As taxpayer you have the right to notice and a hearing prior to the IRS enforcing collection of any tax due.  After the IRS has issued a series a notices, the IRS must issue a Final Notice of Intent to Levy and allow you 30 days to request a hearing, which is generally referred to...Read More

When an asset is placed into service and depreciation is taken as a deduction, the adjusted basis of the asset will be impacted.  The video below has been prepared by a tax attorney at The McGuire Law Firm to discuss this issue.  Please remember to always consult your tax attorney, business attorney, CPA and/or other...Read More