IRS Eases Penalty Assessment Rules for Late-Filed Foreign Gift and Inheritance Forms

    At the urging of the Taxpayer Advocate Service and practitioners, the IRS has ended its practice of automatically assessing penalties at the time of filing for late-filed Forms 3520 to report foreign gifts and inheritances. Also, by the end of the year, the IRS will begin reviewing any reasonable cause statements attached to late-filed Forms 3520 and 3520-A for the trust portion of the form BEFORE assessing any penalty. The IRS previous practice was to automatically assess penalties, even when a reasonable cause statement was attached. The burden was on the taxpayer to raise the reasonable cause argument AFTER...

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Federal Tax Debt and Bankruptcy: Navigating the Legal Landscape for Financial Relief

Bankruptcy Basics Federal courts, in their exclusive jurisdiction over bankruptcy cases, give people and businesses a fresh start when they can no longer pay their debts. There are several chapters of bankruptcy under the United States Bankruptcy Code, but the most common ones for individuals and businesses are: Chapter 7: Involves liquidation, where non-exempt assets are sold to pay off creditors. Individuals or businesses with significant unsecured debts may opt for Chapter 7. Chapter 11: Primarily for businesses, it allows for reorganization and continuation of operations while developing a plan to repay creditors. It’s more complex and costly, often used by...

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The Wilson Firm Awards $1000 Scholarship

The Wilson Firm is pleased to announce that we recently awarded a $1000 scholarship to a deserving student, J.D. Candidate Nga Tran-Medina, at the Thurgood Marshall School of Law. As a leading law firm specializing in tax law, we are committed to supporting the next generation of legal professionals and helping to shape the future of the legal field. Our very own tax attorney, Jay Poynter, had the honor of presenting the scholarship at the Corporate and Tax Law Society Panel. During the panel, Jay spoke about the exciting opportunities and challenges that come with a career in tax controversy. We're...

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Beware of Summertime Scams: IRS Warns Taxpayers of Surging Fraud

The IRS has recently issued a warning to taxpayers, cautioning them to be vigilant about scams promising tax refunds or claiming to "fix" tax-related issues. The IRS emphasizes that it never initiates contact with taxpayers through email, text, or social media regarding tax refunds or bills. They caution against clicking on links from questionable sources and encourage individuals to remain vigilant. These scams often focus on misleading promises regarding a third round of economic impact payments. The IRS has been inundated with complaints, receiving hundreds daily and thousands since the July 4th holiday, directed to their This email address is being protected from spambots. You need JavaScript enabled to view it. email account. The economic...

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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 f...

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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 o...

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Spring Tax Mixer 2023

Yesterday The Wilson Firm organized the Spring Tax Mixer event at Del Frisco's Grille in The Woodlands. More than 20 tax professionals attended this fun networking event, where they were able to connect and exchange ideas, experiences, and opportunities. We had the pleasure of meeting new people, discussing interesting topics, and relaxing after a busy tax season.       We thank every attendee for carving out time for us and stopping by at the event. The Wilson Firm also extends its gratitude to the local businesses that provided generous gifts for door prizes:  VillaSport Athletic Club and Spa,  Black Rock Coffee Bar, Del...

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Tax Made Simple

For business owners, navigating the world of tax compliance can be extremely complicated. On top of the business itself, tax compliance represents a world of confusion for most business owners. The following tips are meant to provide simple, yet highly effective tips on how a business owner can make tax compliance easier. These tips are by no means all-inclusive; they are simply designed to point your business in the right direction. Work as you go. Every year the IRS selects random returns for audits, and those operating small businesses are at a greater risk of being picked up for these random...

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Tax Tips for Business Owners

If you are reading this, I first want to wish you good luck because you are reading this article means you are either running a business or at least thinking of starting a business. When it comes to new business, you may find yourself involved in a variety of different industries, from freight to plumbing or even the restaurant business. However, most entrepreneurs don't realize that they also entered into the tax "industry." Starting a business comes with infinite tax rules to understand and comply with. Because tax is so certain, I think the Bible has a typo: it should say...

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An Introduction to Form 5471

An Introduction to Form 5471 - Information Return of U.S. Persons With Respect to Certain Foreign Corporations   Purpose of Form Form 5471 is used to satisfy the reporting requirements of Internal Revenue Code (“IRC”) §§ 6038 (information reporting with respect to certain foreign corporations and partnerships) and 6046 (returns as to organization or reorganization of foreign corporations and as to acquisitions of their stock). Likewise, Form 5471 is used to report amounts related to IRC § 965 (treatment of deferred foreign income upon transition to participation exemption system of taxation). Certain U.S. persons who are officers, directors, or shareholders in...

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Inside Biden’s Infrastructure Plan: Tax Consequences to be Aware of

I  Making headlines over the past few months has been the Biden administration’s Infrastructure Plan. On September 15, 2021, the House Ways and Means Committee advanced part of the Build Back Better Act, which includes proposed tax changes expected to generate over $2 trillion in federal funds. In total, the House bill is expected to cost $3.5 trillion. In August, the Senate also passed its version of the infrastructure bill, which is limited to $1 trillion in federal spending. According to House Speaker Nancy Pelosi, Biden’s $4.5 trillion infrastructure plan is expected to pass by the end of September. Changes made...

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Basics of an IRS Audit

If there is one word that strikes fear in the hearts of every taxpayer, that word is “audit.”  Most people don’t truly understand what an audit actually entails, why they would be the victim of an audit, and what to do in case they find themselves on the wrong side (implying that there is a right side) of an IRS audit. An IRS audit is an examination of an organization's or individual's accounts and financial information to ensure that information is reported correctly according to tax laws and to verify the reported amount of tax is correct. Many people have the...

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Red Flags and Tax Tips to Help You In Preparing Your Taxes

Don’t Ignore your Tax Preparer’s Red Flags. Tax season is either the best of times or the worst of times. Either you’re eagerly waiting for the Internal Revenue Service (“IRS”) to issue you a juicy refund, or you’re searching and scraping for any deduction or tax strategy that can minimize your tax liability. As the April 18, 2023 deadline is approaching, people might find themselves in “panic mode” and susceptible to making poor decisions this tax season. While there is a temptation to rush your taxes or take “extra” deductions, it is important to understand that when dealing with the IRS,...

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Crypto Crackdown

  Introduction Dogecoin, Shiba, Bitcoin, Ethereum. If none of those sound familiar, then you might have been living under a rock the past few years. From online forums to mainstream news networks, crypto has been a hot topic. We have seen people lose fortunes to crypto, while others got rich seemingly overnight. Because crypto is such a new technology, the final verdict on some of the more complex tax issues related to it are up in the air. While the future holds many uncertainties on how crypto tax issues will be litigated, income that comes from crypto is taxable income like...

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True Love Can Wait (for You to Settle Your Tax Debt)

    Picture this: you are daydreaming about your significant other as you shop for an engagement ring at Tiffany’s. You feel pure bliss as you reminisce about the many years you have spent with them, and then imagine the hopefully numerous years you will spend together in the future. As you look at different rings, imagery of white picket fences, dogs, and 2.5 kids running around flood your mind. In the haze of love and emotion, you are forgetting one thing: your potential soulmate may be drowning in tax debt. With the IRS hiring 87,000 new agents, it is no...

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Tax Provisions of the Inflation Reduction Act of 2022

  A wiseman once said that two things in life are certain: (1) that the government will tax you up until, during, and after your death; and (2) they will make paying taxes as confusing as possible, giving you a headache in the process. Of course, I am paraphrasing a bit. The confusion of endless streams of new tax provisions come with each new administration, and the current one is no exception. Fortunately, at The Wilson Firm, we sift through the mess created by governmental entities like the IRS so you can worry about taxes a bit less. Effective August 16,...

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How Forgiving is Loan Forgiveness?

        Whether you’re for it or against it, the question of what should be done about the almost $2 trillion in student loan debt spread amongst almost 50 million borrowers is a point of political contention. Some people say that we should leave things as they are, and let people figure out how to manage their own student loan debt. Others say that all of the student loan debt should disappear and give all borrowers a clean slate. Finally, those remaining have varying ideas of exactly how much student loan forgiveness is ideal. Wherever you fall on the...

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No Innocent Spouse Relief? No Problem.

If you fail to qualify for Innocent Spouse Relief under Treasury Regulation (“Treas. Reg.”) § 1.6015-2 and Separation of Liability Relief under Treas. Reg. § 1.6015-3, the good news is that you may still be entitled to tax, interest, and penalty assistance through Equitable Relief. What is Equitable Relief? General Conditions for Equitable Relief: According to Revenue Procedure 2000-15, the following threshold conditions must be satisfied before the IRS will consider a claim for Equitable Relief under IRC § 6015(f): The requesting spouse is not eligible for Innocent Spouse Relief, Separation of Liability Relief, or relief from liability arising from community...

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Lee Wilson Certified by the Texas Board of Legal Specialization: Tax Law

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The Wilson Firm is excited to announce that Managing Attorney Lee Wilson is officially certified by the Texas Board of Legal Specialization in Tax Law! 

There are only 191 Board Certified Tax Law Lawyers in the entire state of Texas. 

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Lee Wilson selected to Rising Stars list for the 6th year!

Rising star red 2020

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