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Published Articles
The attorneys at Segal, Cohen & Landis have written articles and legal briefs on a wide range of topics pertaining to tax controversy which have been published in reputable outlets such as Thompson Reuters, Haute Lawyer along with local and national news platforms. They have also served as legal authority in several court cases. Some of those articles are reproduced here for your reference.
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 threshold amount. The FATCA requirement is in addition to the well-established Foreign Bank Account Report (FBAR). Taxpayers who fail to file will […]
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 for the taxpayer, neither of these are true. However, there are limited circumstances that will support […]
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 settlement via an offer in compromise, you might consider a partial pay installment agreement (PPIA). […]
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 worthwhile to understand when, how and to what extent a bankruptcy proceeding will result in the successful removal of your tax […]
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 nonflier or have wondered what the risk may be for opting out of your annual filing requirement, you might be surprised to learn that in these situations the IRS can file a tax return for you, assess […]
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 than 30% of all submitted offers in compromise each year. This article explores which taxpayers might qualify […]
