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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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FinCEN is the Financial Crimes Enforcement Network.  The goal and objective of FinCEN is to monitor financial institutions through regulations that require certain record keeping, record maintenance and reporting.  Because many crimes such as illegal drug trafficking, terrorism and others involve large sums of money and the use of financial institution, FinCEN and other law...
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Are tax liens a matter of public record?  If so, why?  The answer is, yes, a tax lien, such as a notice of federal tax lien filed by the Internal Revenue Service is made public.  The reasoning is the same as to why certain debts are made a matter of public record as it provides notice...
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What is the Offshore Voluntary Disclosure Program?  Often referred to as the OVDP, this program was created to allow taxpayers with foreign financial accounts and interests to voluntarily disclose their interests for a reduced penalty.  Currently the foreign bank reporting requirements require that taxpayers with foreign financial accounts or interests report these interests when the...
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