by Cory Johnson | Jun 29, 2018 | Tax Advice, IRS Collections
Having a “seriously delinquent tax deficiency” as determined under IRC §7345 can enable the IRS to certify an individual’s tax debt to the State Department, which allows the State Department to revoke, deny, or limit an individual’s passport. A taxpayer has “seriously delinquent tax debt” when he or she owes more than $51,000 including late fees and penalties (which is indexed to inflation) and when a levy has been issued or a lien has been filed by the IRS. IRC §7345(b). The right to a Collection Due Process hearing also must have lapsed or have been exhausted in order to be subject to certification.
by Cory Johnson | Mar 14, 2018 | Voluntary Disclosures, International Compliance
The Internal Revenue Service announced yesterday that it will end the Offshore Voluntary Disclosure Program (“OVDP”) on September 28, 2018 and wind it down over the coming months. IR-2018-52. The IRS established the OVDP voluntary compliance program in 2009, with its current incarnation set up in 2014, to allow taxpayers who willfully failed to report foreign bank accounts/assets to come forward voluntarily without fear of criminal liability, and to limit their civil penalties on specified terms.
by Cory Johnson | Oct 31, 2017 | International Compliance, Tax Advice
FIRPTA, or the Foreign Investment in Real Property Tax Act, is part of the United States’ continued efforts to tax all income/gain connected to the United States. Real estate agents, escrow agents, and buyers should be aware of FIRPTA because it mandates income tax withholding and paying over to the IRS 15% of the sales price on the purchase of a U.S. real property interest from a foreign person under certain circumstances. 26 U.S.C. § 1445. In other words, buyers may not be able to pay all of the purchase price to the seller—some may have to be paid to the IRS. This can include situations where a foreign person (or entity) sells, exchanges, liquidates, redeems, gifts, or transfers in any other way a real property interest. The obligation is imposed on a buyer as well as a buyer’s agent and/or settlement/escrow officer.
by Cory Johnson | Oct 10, 2017 | Washington State Tax Appeals, Washington State Tax Audits
In the last few weeks we have received calls from several companies that have received Washington Business Activity Questionnaires regarding their affiliation with Amazon fulfillment centers. We believe the Washington State Department of Revenue (DOR) may have opened a project targeting out of state vendors who may unknowingly have Washington contacts through fulfillment centers located in Washington.
by Cory Johnson | Sep 27, 2017 | IRS Collections
Taxpayers who don’t file their returns on time may think that the late filing/payment penalties and interest are the worst part about filing tax returns well after the deadline. But self-employed taxpayers should be aware of another harm that could haunt them in the future: losing out on Social Security retirement benefits.
By way of quick background, to be eligible for Social Security retirement benefits, a person must have wages or net self-employment earnings for 40 quarters (i.e., earn 40 “credits”).
