Another Win in a Streamlined Domestic Offshore Disclosure Case
Blog Manager
Results
Offshore Tax Reporting Requirements for Foreign Accounts and Retirement Plans U.S. taxpayers with financial interests in foreign bank accounts or foreign retirement plans are subject to strict reporting requirements under U.S. tax law. These obligations may include disclosing foreign financial accounts and certain retirement plans on annual tax ret...
The Wilson Firm’s Legal Victory for a Fortune 100 Corporation
Blog Manager
Results
How Property Tax Appeals Work for Commercial Real Estate Local appraisal districts determine the taxable value of commercial real estate for property tax purposes. When a property owner believes the appraisal district has overvalued their property, they can challenge the valuation through administrative protest procedures and, if necessary, litigat...
Representation of Investor in Acquisition of Two Equipment Rental Locations via Sale-Leaseback
Richard James
Results
How Sale-Leaseback Transactions Work in Commercial Real Estate Sale-leaseback transactions are a common structure in commercial real estate where a business sells its property to an investor and then leases it back to continue operating at the same location. For investors, these transactions can provide stable rental income supported by an operatin...
U.S. Tax Court Settlement Reduces Proposed IRS Assessment from $238,245 to $67,836
Jack Naranjo
Results
How IRS Notices of Deficiency Lead to Tax Court Disputes When the IRS determines that a taxpayer has underreported income, it may issue a Notice of Deficiency proposing additional tax, penalties, and interest. This notice gives the taxpayer the right to challenge the assessment by filing a petition in the United States Tax Court. Tax disputes invol...
$10+ Million Commercial Real Estate Sale-Leaseback Transaction
Richard James
Results
How Sale-Leaseback Transactions Work in Commercial Real Estate Sale-leaseback transactions are a common structure in commercial real estate where a property owner sells real estate to an investor and leases it back for continued business operations. This structure allows operating companies to unlock capital tied up in real estate while maintaining...
How a $672,057 Trust Fund Recovery Penalty Was Resolved for $2,049
Julia Salzman
Results
What Is a Trust Fund Recovery Penalty and How the IRS Enforces It A Trust Fund Recovery Penalty (TFRP) is one of the most serious payroll tax enforcement actions the IRS can impose. When employment taxes are not properly remitted, the IRS may assess personal liability against individuals deemed responsible for collecting and paying those taxes. Unl...
IRS Proposed Tax Assessment Withdrawn After Section 121 Residency Documentation
Julia Salzman
Results
What Is the Section 121 Principal Residence Gain Exclusion? When a taxpayer sells a principal residence, the Internal Revenue Code allows eligible homeowners to exclude a portion of the gain from taxable income under Section 121. Individuals may exclude up to $250,000 of gain, while married couples filing jointly may exclude up to $500,000 if they ...

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