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In Uncategorized by Edward CortsLeave a Comment

The Texas Comptroller announced on March 25, 2020, that it is offering assistance to businesses that are potentially struggling to pay the full amount of the Texas sales tax that they collected in February, 2020.  For affected businesses, the Texas Comptroller is offering short-term payment agreements to pay the collected sales taxes, with the waiver of penalties and interest, in …

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International Reporting Penalties

In FBAR, Fines, International Tax, Penalties, Uncategorized by Ryan DeanLeave a Comment

Taxpayers with interests in foreign financial assets, financial accounts, and/or foreign trusts may have certain tax reporting obligations with the IRS.  For example, taxpayers with a financial interest in or signature authority over foreign financial accounts with an aggregate value of over $10,000 at any time during the calendar year must file a Report of Foreign Bank and Financial Account …

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Where Is the Limit on Penalties for Willful FBAR Violations?

In Bank Fraud, Evasion, FBAR, Fines, Fraud, International Tax, Uncategorized by Ryan DeanLeave a Comment

A recent decision of the United States Court of Appeals, Federal Circuit holds that the pre-2004 regulation limiting willful FBAR penalties to a maximum of $100,000 is notapplicable.  As many tax practitioners know, 31 U.S.C. § 5314(a) requires taxpayers who have accounts with foreign financial institutions, specifically any person with a financial interest in or signature authority over foreign financial …

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Advising Domestic Business Ventures: Section 199A and Flow-Through Structures

In Uncategorized by Jason B. FreemanLeave a Comment

Freeman Law advises domestic and international ventures with corporate and tax compliance.  Clients with flow-through entity structures may need to consider the impact of section 199A.  Planning for section 199A may significantly impact a client’s bottom line and investor returns.  For more on section 199A, see our other Insights, such as A Practical Roadmap Through Section 199A, Choice of Entity After …

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Taxes and Bankruptcy: IRS-Prepared Substitute Returns

In Bankruptcy, Uncategorized by freemanlawdevLeave a Comment

A taxpayer filing for bankruptcy with unfiled tax returns faces potential pitfalls. In order to ensure that a debtor’s federal tax liability is discharged in the bankruptcy, the potential bankruptcy debtor must know and comply with the requirements of the circuit where the debtor will file their bankruptcy petition. The recent case of In re Forrester demonstrates several of the …

Major Changes are in Store for the Partnership Audit Rules

In Partnership Tax, Uncategorized by Jason B. FreemanLeave a Comment

The partnership audit rules are in for a major overhaul. The recently-enacted Bipartisan Budget Act of 2015 (BBA) is replacing the existing partnership audit framework with a new regime. The new rules, however, are not immediately mandatory—they will generally apply “to returns filed for partnership taxable years beginning after Dec. 31, 2017.” So, for many partnerships, now is the time …