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.

The FBAR and Foreign Bank Accounts

The FBAR and Foreign Bank Accounts


U.S. taxpayers who have financial accounts abroad may be required to disclose these assets to the IRS by filing a Foreign Bank Account Report (FBAR).  This filing requirement extends to US citizens residing within the country as well as to Americans living and working abroad. Given that the failure to comply may draw unwanted attention […]
Personal Responsibility for Payroll Tax Liability

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 unsparing IRS penalties and is on the hook to satisfy the unpaid payroll tax as well as […]
Non-U.S. Citizens: Filing Requirements and Tax Treatment

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 income, on income from a trade or business in the U.S., […]
Challenging IRS Collection Action via the Collection Due Process Appeal

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 have federally recognized due process rights which require that the IRS provide taxpayers with notice and an opportunity […]
A Taxpayer’s Guide to Compliance Under FATCA

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

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 […]

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