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The Who, What, When and Where of IRS Form 8938, Statement of Specified Foreign Financial Assets
IRC Section 6038D requires any taxpayer who has an interest in a "specified foreign financial asset" to disclose that asset to the IRS on a Form 8938 attached to the taxpayer’s annual tax return. The...
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The Statute of Limitations for Assessment: The Taxpayer's Ultimate Defense to the IRS' Assessment of
One of the questions taxpayers regularly ask is: How long does the IRS have to propose and assess additional tax? Or as some taxpayers put it, " How long before I can be sure I am safe from the IRS...
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To Rule or Not to Rule: IRS Updates for 2023 its No-Ruling Lists for Private Letter Rulings
Should you need either 100% tax certainty or the IRS to fix a past mistake, a private letter ruling may be the answer for you. There are areas, however, where the IRS will not issue a ruling. And fo...
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IRS Form 8275: To Disclose or Not Disclose -- That Is The Question | Meadows, Collier, Reed, Cousins
At least once in their career most tax return preparers have faced the dilemma of whether and how to make a disclosure with a tax return. A disclosure is an extra explanation beyond the usual income ...
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IRS Administrative Summons to a Taxpayer: The Taxpayer's Duties and Rights | Meadows, Collier, Reed
In most IRS examinations, the taxpayer and the IRS prefer an informal information-gathering process with the IRS issuing Information Document Requests (IDRs) and the taxpayer providing responses. Howe...
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IRC Section 6901 and Transferee Liability | Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L
In a previous blog post, I discussed a case involving the liability of an executor for unpaid federal estate taxes. In this blog post, I will discuss the basics of transferee liability for a transfer...