Strategic S Corp Conversion to Avoid Tax Basis Limitation
Houston Tax Attorney Blog
by KD Mitchell, JD LLM
1w ago
Time. We can’t stop it, but we can use it. We can use it to take advantage of compounding to grow our savings. We can use it to pay down debt to increase equity. And we can use it for tax planning. Time is one aspect of tax planning. It can help taxpayers avoid just… The post Strategic S Corp Conversion to Avoid Tax Basis Limitation appeared first on Houston Tax AttorneysMitchell Tax Law ..read more
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Income Shifting to Reduce Tax for Real Estate Sale
Houston Tax Attorney Blog
by KD Mitchell, JD LLM
3w ago
Income shifting is a fundamental income tax planning concept. It involves strategically allocating income among related taxpayers to minimize the overall tax liability. This may be intended to use up tax attributes of one taxpayer (such as deductions or tax credits), take advantage of tax deferral options to delay paying taxes, or take advantage of… The post Income Shifting to Reduce Tax for Real Estate Sale appeared first on Houston Tax AttorneysMitchell Tax Law ..read more
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Court Says IRS Can Assess Form 5471 Penalties
Houston Tax Attorney Blog
by KD Mitchell, JD LLM
1M ago
Our federal tax system is code-based. This means that most of what the law is can be found in statutes. The premise is that one can read the statutes and get a general idea of what the law is. This is why when it comes to tax law, each word matters. Adding or removing a… The post Court Says IRS Can Assess Form 5471 Penalties appeared first on Houston Tax AttorneysMitchell Tax Law ..read more
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Third-Party Liability for Repaying Employee Retention Credits
Houston Tax Attorney Blog
by KD Mitchell, JD LLM
1M ago
Many businesses outsource their human resources to third parties called Professional Employer Organizations (“PEOs”). PEOs are particularly popular with small businesses. The benefits of using a PEO include allowing the business to focus on its business operations rather than HR activities and giving employees access to better employee benefits. This is achieved by having the… The post Third-Party Liability for Repaying Employee Retention Credits appeared first on Houston Tax AttorneysMitchell Tax Law ..read more
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Who Gets Paid First: the Family Member or the IRS?
Houston Tax Attorney Blog
by KD Mitchell, JD LLM
2M ago
When someone owes the IRS money, chances are good that they have other creditors who are also owed money. This raises questions as to who gets paid first–the third parties or the IRS. The answer is usually the IRS–if the IRS even bothers to attempt to collect. In many cases, the IRS does not ever… The post Who Gets Paid First: the Family Member or the IRS? appeared first on Houston Tax AttorneysMitchell Tax Law ..read more
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Tee Time on Taxpayers’ Dime: IRS Employee Golfing on the Job
Houston Tax Attorney Blog
by KD Mitchell, JD LLM
2M ago
The IRS cannot simply terminate employees as private-sector employers can. IRS employees are often shielded by complex bureaucratic processes that makes it difficult to remove them from their positions. The recent case of Sheiman v. Department of the Treasury, No. 2022-2045 (Fed. Cir. 2024), provides an opportunity to consider the IRS’s challenges in terminating an… The post Tee Time on Taxpayers’ Dime: IRS Employee Golfing on the Job appeared first on Houston Tax AttorneysMitchell Tax Law ..read more
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About “Sandbagging” in Tax Litigation
Houston Tax Attorney Blog
by KD Mitchell, JD LLM
2M ago
The litigation process requires parties to adhere to various procedural rules. These rules are intended to ensure fairness and efficiency in the court process. One of the most critical aspects of this process is the discovery phase, where parties exchange information and evidence relevant to the case. Some litigants may attempt to gain an unfair… The post About “Sandbagging” in Tax Litigation appeared first on Houston Tax AttorneysMitchell Tax Law ..read more
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IRS Can Sidestep Taxpayers’ CDP Rights by Applying Overpayments
Houston Tax Attorney Blog
by KD Mitchell, JD LLM
2M ago
Imagine that Congress sets out a remedy to curb IRS abuses. And further consider that after the taxpayer pursues the remedy, the rules allow the IRS to simply sidestep the remedy. So the remedy is no remedy at all. That is what we have in the Zuck v. Commissioner, No. 25125-14L (U.S.T.C. Apr. 6, 2022)… The post IRS Can Sidestep Taxpayers’ CDP Rights by Applying Overpayments appeared first on Houston Tax AttorneysMitchell Tax Law ..read more
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Tax Form Mixup Can Extend the IRS’s Statute of Limitations
Houston Tax Attorney Blog
by KD Mitchell, JD LLM
3M ago
Suppose you file a tax return and, months or years later, you get a letter from the IRS saying that it will not accept the tax return. The IRS letter says that you used the wrong tax form. And maybe even change the facts so that the IRS mailed this letter to you, but you… The post Tax Form Mixup Can Extend the IRS’s Statute of Limitations appeared first on Houston Tax AttorneysMitchell Tax Law ..read more
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The “Effective Date” for Tax Rules
Houston Tax Attorney Blog
by KD Mitchell, JD LLM
3M ago
At the end of every tax statute, there is language that specifies when the new tax rule is effective. Given the frequency with which Congress enacts new tax laws, often several times every year, one might think that there is no dispute as to the “effective date” language that it uses. One might think that… The post The “Effective Date” for Tax Rules appeared first on Houston Tax AttorneysMitchell Tax Law ..read more
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