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A Son Bears the Sins of His Father: Bontrager v. Commissioner

In Restitution by Zach MontgomeryLeave a Comment

In the Greek dramatist Euripides’ tragedy, Phrixus, there is the following line: “The gods visit the sins of the fathers upon the children.” Such words are no more applicable than in the case of Bontrager v. Commissioner. According to the Tax Court, the Internal Revenue Service (“IRS”) was authorized (under I.R.C. § 6201(a)(4)) to assess restitution against Mr. Bontrager, the …

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Advising International Business Ventures: Tax Reform’s Section 245A Participation Exemption Regime

In International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post focuses on, and provides a short …

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The Basics of the Trust Fund Recovery Penalty

In Trust Fund Penalty by Jason Freeman and Katie ManworrenLeave a Comment

Section 6672(a) of the Internal Revenue Code, known as the trust fund recovery penalty, allows the IRS to collect unpaid payroll taxes from individuals who are found (1) to be responsible for collecting or paying withheld income and employment taxes on behalf of an employer, and (2) to have willfully failed to pay the taxes. The IRS generally only collects …

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Innocent Spouse Relief

In Innocent Spouse Relief by Ryan DeanLeave a Comment

Most married couples file their taxes jointly due to its advantages over filing separately.  But most couples do not realize that when they file a joint return they are actually jointly and severally liable for the tax owed.  This means that the IRS can hold either spouse fully liable for the tax owed, regardless of who incurred the tax or …

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Second Installment: Advising International Business Ventures: Tax Reform’s “Transition” Tax

In International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post focuses on, and provides a second …

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Advising International Business Ventures: Tax Reform’s “Transition” Tax

In International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post focuses on, and provides a short …

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Federal Securities Law – Investment Contracts, the Silent Security

In Securities by Ryan DeanLeave a Comment

The Securities Act of 1933 (the “Act”) provides a number of protections for investors.  The purpose of the Act is to require issuers to provide financial or other significant information to investors when the issuer offers securities for public sale. The Act allows an investor to recover losses if the investor can show that the issuer did not fully or accurately …

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Advising Domestic Business Ventures: Section 199A and Qualified Business Income (“QBI”)

In 199A, QBI by Jason FreemanLeave a Comment

Freeman Law advises domestic and international ventures with corporate and tax compliance.  Clients with flow-through entity structures may need to consider the impact of section 199A.  Planning for section 199A may significantly impact a client’s bottom line and investor returns.  This resource provides additional background on the concept of Qualified Business Income (“QBI”) for section 199A purposes.   Section 199A …

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Advising Domestic Business Ventures: A Trade or Business for Purposes of Section 199A

In 199A by Jason FreemanLeave a Comment

Freeman Law advises domestic and international ventures with corporate and tax compliance. Clients with flow-through entity structures may need to consider the impact of section 199A. Planning for section 199A may significantly impact a client’s bottom line and investor returns. This resource provides additional background on the concept of a trade or business for section 199A purposes. Section 199A was …

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Advising International Business Ventures: Tax Reform’s New GILTI Tax

In GILTI, International Tax, Tax Reform by Jason FreemanLeave a Comment

Freeman Law frequently advises international business ventures. International operations often give rise to unique (and sometimes unanticipated) compliance obligations and complex reporting requirements. Recent tax reform rules and regulations have imposed a number of new requirements.  The IRS and Treasury Department have elaborated on these new rules through proposed regulations and other guidance.  This post focuses on, and provides a short …