What constitutes willful versus non-willful conduct in the eyes of the IRS? Why is this distinction important to the agency, especially regarding international disclosures and taxable events? We are often asked about how seriously the IRS takes “willful” conduct into account as it applies to an audit or tax-related investigation. ...
What is the IRS Offshore Voluntary Disclosure Program?
What is the IRS Offshore Voluntary Disclosure Program and who is it designed to help? What are the guidelines for voluntary disclosure to the IRS and who is eligible to apply? The IRS Offshore Voluntary Disclosure Program is designed for US taxpayers who have not made a full disclosure of...
IRS Tax Refunds are Lower for Tax Year 2023 Thus Far
Did you know IRS tax refunds are lower for tax year 2023 thus far when compared to the same point a year ago? While the IRS just began accepting tax returns for tax year 2023 on January 29 of this year, there is already one troubling statistic according to the...
IRS Provides 2023 Tax Return Preparation and Filing Tips
Are you searching for 2023 tax return preparation and filing tips? The window officially opened to submit 2023 tax returns to the IRS on January 29, 2024. The following day the IRS released IR-2024-38, “Things to remember when filing 2023 tax returns” including return preparation and filing tips to help...
What Does the Recent OTA Ruling Tell You About a California Tax Audit?
What does the recent OTA ruling tell you about a California tax audit? What can we learn from the results of an investigation by the Office of Tax Appeals (OTA) into the practices of a California tax agency? Why do you need an experienced San Diego tax attorney if you...
It’s Time to Start Making Estimated Tax Payments Again California
The IRS and the State of California provided significant relief to millions of taxpayers across our state last year extending deadlines for estimated tax deposits, as well as personal and business tax returns. It’s time to get back into the discipline of tax planning and start making estimated tax payments...
A Decision in US Tax Court Affects Limited Partners and SECA
A recent decision in the US Tax Court affects limited partners and SECA – the Self Employed Contributions Act. In this case, Soroban Capital Partners LP (a hedge fund management company) was formed as a Delaware limited partnership and had excluded self-employment tax (under SECA) and associated levies on millions...
How Does the IRS Use AI to Identify Tax Cheats?
Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In a recent interview, IRS Commissioner Danny Werfel began to lay out a vision...
Do You Have to Pay Taxes When Selling Goods or Services Online?
We are often asked if one has to pay taxes when selling goods or services online. That question became even more relevant this week when the IRS postponed the new “$600 Rule.” This is a particular relief for those wo receive payments through popular third party payment applications such as...