The California Tax Attorney Blog covers tax controversies, probate, estate planning, and business transactions. It is published by Mitchell A. Port.
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Standards Clarifying When Federal Employment Taxes Are Paid By Employee Leasing Companies Or By The Employer
California’s employers as well as employers throughout the U.S. are required to withhold and pay Federal employment taxes (consisting of Federal Insurance Contribution Act –FICA- taxes and Federal Unemployment Tax Act –FUTA- taxes with respect to wages paid to their employees. The one determined...
The Government Proposes To Increase Certainty With Respect To Worker Classification Current Law For both tax and nontax purposes, workers must be classified into one of two mutually exclusive categories: employees or self-employed (sometimes referred to as independent contractors). Worker...
REVISED OFFER IN COMPROMISE APPLICATION RULES I would like to pay particular attention to the president’s recent budget proposals submitted to Congress that directly impact my clients who have IRS tax problems and disputes. One proposal that would be effective for offers-in-compromise submitted...
Internal Revenue Code Section 7430(a) provides that the prevailing party in any administrative or court proceeding may be awarded a judgment for (1) reasonable administrative costs incurred in connection with such an administrative proceeding within the IRS, and (2) reasonable litigation costs...
For 2012, no late filing penalties apply when missing the April 15 tax filing deadline. That's because for this year, the federal tax filing deadline is April 17. Since April 15 falls on a Sunday, the deadline is moved to the following Monday; but because Monday is Emancipation Day in Washington,...
Right after the New Year, the Internal Revenue Service released new proposed guidelines designed to provide relief to more innocent spouses requesting equitable relief from income tax liability. In an earlier blog post, other rule changes were discussed. A Notice proposing a new revenue procedure...
JK Harris & Co. - "the nation's largest tax representation firm" - is in bankruptcy. It may stop trying to restructure its business to liquidating its business instead. This case shows how hard it can be to settle tax disputes for “pennies on the dollar”. JK Harris advertised that it could...
As of this past Monday, the Internal Revenue Service reopened the offshore voluntary disclosure program to help people hiding offshore accounts get current with their taxes and announced the collection of more than $4.4 billion so far from the two previous international programs. The IRS reopened...
California became the seventh state to adopt two new subtypes of stock corporations — a “flexible purpose corporation” and a “benefit corporation" as of January 1, 2012. Now, investors and entrepreneurs can pursue both social and economic objectives allowed by the new corporation subtypes. These...
You may be familiar with the so-called "national standards" used by the Internal Revenue Service in calculating repayment of delinquent taxes. As of October 3, 2011, new "standards" were issued. Those standards are used so that all taxpayers located in a particular locale are treated the same as...