IRS Tax Attorney Blog
Attorney-written guides on IRS audits, tax debt, wage garnishment, offshore accounts, and California tax issues — by Samuel Landis, Esq.
Unraveling the Mystery of IRS Tax Liens: Prevention, Resolution, and Payroll Tax Attorney Expertise
The Internal Revenue Service (IRS) is legally empowered to claim a tax lien against a taxpayer’s property when taxes remain unpaid, potentially wreaking havoc on a taxpayer’s financial well-being and credit score. A…
IRS Tax Fraud: Are You at Risk?
A variety of actions ranging from simply failing to file your tax return to being involved in a complex offshore tax evasion scheme might warrant the imposition of civil penalties or expose you to criminal liability…
IRS Currently Not Collectible Status
If you can establish that you have insufficient income with which to pay a federal tax bill such that paying any tax due would cause a significant financial hardship, the IRS may forgo collection efforts for a period…
The IRS Alter Ego Theory of Liability
When a taxpayer has an outstanding tax liability, the IRS has authority, subject to due process considerations, to seize the taxpayer’s personal assets such as bank accounts, wages, and property to satisfy the tax…
Personal Responsibility for Payroll Tax Liability
You probably are familiar with an employer’s obligation to withhold payroll taxes from each employee’s wages and submit these funds to the IRS on a regular basis. When a company fails to do so, it is subject to…
Non U.S. Citizens Filing Requirements and Tax Treatment
If you are not a U.S. citizen you may be wondering whether you need to file a tax return in the United States and to what extent you are required to pay federal income tax. Will you be required to pay tax on worldwide…
Challenging IRS Collection Action via the Collection Due Process Appeal
When you have outstanding tax liabilities, the IRS has the authority to pursue collection of your tax debt by filing a tax lien against you, garnishing your wages, or taking money out of your bank account. Taxpayers…
A Taxpayer’s Guide to Compliance Under FATCA
Under the Foreign Account Tax Compliance Act (FATCA), U.S. citizens, including Americans living abroad, are required to report their foreign assets to the Internal Revenue Service (IRS) if they exceed a certain…
IRS Interest Accrual and Abatement
Many taxpayers believe that if they pay an outstanding tax bill, the IRS will forgive the interest, or, if they set up a payment plan with the IRS, interest will no longer accrue on the unpaid balance. Unfortunately…
IRS Partial Pay Installment Arrangements An Overlooked IRS Resolution Alternative
When you are faced with an overwhelming tax liability that you can’t fully pay based on your current financial circumstances, and where you don’t have enough savings to make a lump sum payment to the IRS as part of a…
Discharging Tax Debt in Bankruptcy
While it is true that most tax debt cannot be eliminated by filing for bankruptcy protection, under some circumstances outstanding tax liabilities can get discharged when you or your business become insolvent. It is…
Understanding the Substitute for Return: When the IRS Files a Tax Return for You
Each year hundreds of thousands of taxpayers forgo filing their federal income tax returns. If you are a nonfiler or have wondered what the risk may be for opting out of your annual filing requirement, you might be…
The IRS Offer in Compromise: A Taxpayer’s Guide to Settlement with the IRS
While it is not a myth that some taxpayers can settle significant tax debt with the IRS for considerably less, the circumstances which support this type of resolution are quite specific. In fact, the IRS accepts less…
The Complete Guide to Form 3520: Who Files, When, and What Happens If You Don't
The Complete Guide to Form 3520: Who Files, When, and What Happens If You Don’t Publishing Notes for SCL Recommended use: update and expand the existing SCL article at IRS Form 3520: Reporting Requirements Involving…
The Coveted Home Office Deduction: Do You Qualify to Claim It?
More people than ever before are working from home, however not everyone can claim the home office deduction on their federal income tax return. The IRS rules regarding who can deduct expenses for maintaining a home…
The Federal Tax Levy: A Harbinger of Exaction
The Internal Revenue Service has sweeping powers in the form of the federal tax levy to collect when you don’t pay your taxes. It can take a significant portion of your paycheck, freeze or seize the funds in your bank…
Selling Property Subject to a Federal Tax Lien
As discussed in our last article, “The Federal Tax Lien: A Staple of IRS Enforcement Action,” the Internal Revenue Service will file a tax lien against you when you fail to pay your taxes. The lien attaches to all…
The Federal Tax Lien: A Staple of IRS Enforcement Action
Every year the Internal Revenue Service files hundreds of thousands of tax liens against individuals and businesses that have not paid their taxes. Federal tax liens jeopardize your assets, affect your credit, and can…
Cash Payment Apps & New IRS Reporting Requirements
By January 31, people across the country will have received various tax forms containing information to be included in their annual federal income tax returns. Given some of the new Internal Revenue Service reporting…
Unfiled Tax Returns: Consequences and Compliance
Most taxpayers are required to file a tax return each year; however, some have neglected to do so and find themselves overwhelmed with the task of catching up. Reasons abound to justify a decision not to file including…
What To Do When You Disagree with an IRS Audit
Typically, an IRS examination of one’s tax return will result in the assessment of additional taxes, penalties, and interest. Most taxpayers disagree with their auditor’s findings and want an opportunity to challenge…
Are You at Risk of an IRS Audit and How Far Back Can the IRS Go?
The IRS conducts hundreds of thousands of audits a year, typically resulting in the taxpayer owing significantly more tax. Most people shudder at the thought of having their tax return examined by an auditor and worry…
What is the Difference between the IRS Fresh Start Program and an Offer in Compromise?
What is the Difference between the IRS Fresh Start Program and an Offer in Compromise? You may have seen advertisements about tax relief available through the IRS Fresh Start program for taxpayers who qualify. You…
IRS Delinquencies & Passport Restrictions: What You Need to Know
You may be surprised to learn that having an unpaid tax bill with the federal government could potentially hamper your ability to travel or live abroad. Each year hundreds of taxpayers with IRS delinquencies encounter…