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IRS issuing a series of urgent letters to over 10,000 taxpayers regarding their virtual currency transactions

The IRS started sending out letters mid-July to taxpayers who have participated in virtual currency transactions. The letters consist of three different versions: Letter 6174, Letter 6174-A, and Letter 6173. Each letter’s intention, according to the IRS, is to “strive to help taxpayers understand their tax and filing obligations and how to correct past errors.” But each letter sends a different message. While Letters 6174 and 6174-A can be considered “soft” notices, Letter 6173 alleges noncompliance by stating that you “may not have met your U.S. tax filing and reporting requirements for transactions involving virtual currency...” IRS Commissioner Chuck Rettig recently stated:

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Lee Wilson selected to Super Lawyers' Rising Stars for third consecutive year

The Woodlands, Texas - Lee Wilson, Managing Attorney of The Wilson Firm, PLLC, was selected to Super Lawyers' Rising Stars again this year, making it three consecutive years that he has been honored accordingly.  The Rising Stars designation is reserved for the top two-percent (2%) of attorneys in Texas.
The Wilson Firm is a boutique tax law firm dedicated to helping individuals and businesses involved in disputes with governmental taxing authorities at the federal, state, and local levels.  We strive to provide our clients with top-notch service at reasonable rates, and most importantly, top-notch results.  Our goal in representing clients in contested tax matters is to resolve the matter as early in the process as possible in a manner that achieves the economic objectives of our client. Our approach to each case is simple: we make sure that each and every option available to the client is explored, and the client walks away knowing they've received the optimal solution to their problem.
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Is the TSA still the biggest headache for vacation travelers? For some, the IRS is about to jump to the front of the line.

The Woodlands, Texas - Last month, a few tax-related measures were slipped into H.R. 22, known as the "Fixing America's Surface Transportation Act." These provisions could add some significant teeth to the IRS' ability to collect past-due tax debts at a time when budget shortfalls have limited the agency's ability to do so efficiently. They include the addition of a new section to the Internal Revenue Code, I.R.C. § 7345, which authorizes the Treasury Secretary to certify that a taxpayer has a "seriously delinquent tax debt." A "seriously delinquent tax debt" is defined as a federal tax liability which been assessed and is greater than $50,000, and for which the IRS has either filed a lien or otherwise issued a final levy notice. This certification will be issued by the IRS to the Secretary of State, and authorizes the Secretary of State to deny, revoke, or otherwise limit that taxpayer's U.S. passport. There are notable exceptions to the new law, most generally applicable when the taxpayer has already entered into an arrangement to satisfy the tax obligation (via an installment agreement or offer in compromise), or otherwise has a pending request disputing the amount of the assessed delinquency. If the taxpayer is abroad at the time their passport is revoked, the revocation can be limited to allow for the taxpayer to return to the United States.

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Are they employees or independent contractors? How they may actually be BOTH...and the IRS might agree...sort of.

The Woodlands, Texas - For business owners, the decision on how to classify those who work for them is very important. It's been known for a while that worker classification matters are one of the key target areas for the IRS, and in an era of constant cutbacks and budget shortfalls, it's an area that will continue to have their attention. As recently as the summer of 2014, the IRS announced that it was stepping up its audits of S Corporations, largely due to what has been perceived as abuses in this area. Combined with a joint information-sharing initiative between the IRS and the U.S. Department of Labor to ensure that such misclassifications are minimized, it's clear that this is an area of focus among multiple government agencies and demands attention from business owners and their advisors.

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Introducing the U.S. Tax Court Podcast

The Woodlands, Texas Below is a link to a new podcast created by myself and Rik Thakrar, a fellow tax lawyer in Orlando, Florida. The weekly podcast focuses on practice in the U.S. Tax Court from our perspective as practicing attorneys. The really great part about the podcast is we focus on the history leading up to certain cases, the law to come out of those cases and application of such law to practice in the court today. We've gotten a really great response to the first 3 episodes, and I hope you enjoy listening to the podcast as much as Rik and I have enjoyed making it.
You can subscribe to the Podcast by clicking the "Subscribe" button underneath the podcast logo after following the link below.
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When should a CPA call in a tax lawyer? Read the Defense.

The Woodlands, Texas - Now that tax season is over and many CPAs are "relaxing" by getting back to their regular 10-12 hour days (or hopefully taking some well-deserved vacation), I thought it was a great time to share an article published in the Journal of Accountancy entitled "10 situations when a CPA should call "timeout"" that essentially lays out a list of instances when CPAs might be in situation where calling in legal counsel is in their (and more importantly their client's) best interest. It's a well-written but somewhat long article, and it was published on April 13th, so I feel pretty confident that most CPAs didn't even notice it then because they were pretty busy to put it lightly. Here's a link to the article:http://www.journalofaccountancy.com/issues/2015/apr/when-tax-accountants-should-call-legal-counsel.html

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An extension worth seven figures? For clients with undisclosed offshore accounts, filing an extension can mean much more than simply buying time.

The Woodlands, Texas - With April 15th now less than one week away, taxpayers and their CPAs are busy gathering any additional information necessary to complete their returns on time. In some cases, that information can't be realistically obtained in time to make sure the return will be filed correctly, so thousands of taxpayers will (or already have) submit Form 4868, which grants an automatic extension of the deadline to file the tax return for 6 months. For taxpayers with foreign bank accounts that have yet to be disclosed to the IRS via the normal FBAR filing requirement or, alternatively, through one of the IRS' current voluntary disclosure programs, filing the extension can prove much more valuable than simply allowing additional time.
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The Woodlands, TX

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  The Wilson Firm
2700 Research Forest Dr.
Suite 124
The Woodlands, Texas 77381


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