OVDP and the IRS’s New Streamlined Filing Procedures
The IRS’s Offshore Voluntary Disclosure Program (OVDP) is designed to assist U.S. taxpayers who have failed to properly report or pay income taxes on offshore financial accounts. When the U.S....
View ArticleCasualty Loss Deductions and Other Hurricane-Related Tax Benefits
Editor’s Note: This article was originally published in February 2013 as “Casualty Losses for Property Damaged by Hurricane Sandy” and has been updated to address the similar issues raised by the...
View ArticleGift Horse or Trojan Horse?
It is the worst-case scenario for many individual taxpayers: a lien on their property. While a lien is not the same as seizure, as the property remains in the taxpayer’s possession, it does give the...
View ArticleMaterial Participation as Significant Participation Activity
A recent case serves as a convenient reminder for 2020 tax return elections. In Gurpreet S. Padda, et al. v. Comm’r (TCM 2020-154), a physician met the test for significant participation activities...
View ArticleRental Activity and Self-Employment Tax
Tax planning for real estate activities often involves a myriad of tax considerations. For example, if the real estate produces a loss, a determination must be made whether the loss is limited by...
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