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If you have reviewed partnership agreements or operating agreements for an LLC you have probably read provisions relating to Minimum Gain Chargeback.  That being said, the Minimum Gain Chargeback provisions may have put you to sleep, and may not even be practical based on the facts and circumstances of the partnership.  However, Minimum Gain Chargeback...
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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...
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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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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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Are distributions from a nondeductible IRA, such as a Roth IRA taxable?  IRS Form 8606 can be used to calculate the taxable amount (if any) from a nondeductible IRA. The Video below has been prepared by a tax attorney at The McGuire Law Firm to provide additional information regarding Form 8606.  You can speak with a...
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Taxpayers may receive a IRS Supporting Document Request from the Internal Revenue Service requesting supporting documents for certain items, issues or positions taken on a tax return.  Common issues of which the IRS would request a taxpayer support could be IRS Filing Status.  For example, if a taxpayer filed head of household, the IRS may...
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