Collection: Expatriation with No Tax, Interest or Penalties: New Relief Procedures for Certain Former Citizens

This article was originally published in the Journal of Tax Practice and Procedure, August – September 2019 edition. Introduction On September 6, 2019, the Internal Revenue Service (IRS) announced the new “Relief Procedures for Certain Former Citizens” (IRS Relief Procedures) who relinquished their United States (U.S.) Citizenship after March 18, 2010.1 Under the new IRS Relief Procedures,…

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Collection: Disputing a Notice of Federal Tax Lien Before It Is Filed

I. Introduction Internal Revenue Service (“IRS”) bank account levies and wage garnishments count among the scariest tax collection weapons in the U.S. Treasury arsenal. However, the Notice of Federal Tax Lien (“NFTL”) can, in many cases, pose a more immediate and substantial threat to individuals and businesses with outstanding tax liabilities. In January 2018, the…

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Collection: When Uncle Sam Crosses the Border: What is in the IRS International Collection Toolbox?

This article was originally published in the Journal of Tax Practice and Procedure, April – May 2019 edition. The Internal Revenue Service (“IRS”) faces many challenges when attempting to collect unpaid taxes from taxpayers with foreign assets who reside abroad (“international delinquent taxpayer” or “IDT”). Common obstacles include locating and contacting the taxpayer, the increasing complexity of international…

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Collection – Pre-Notice Levies: When the IRS Can Levy Before Notifying Taxpayers of Their Right to a Hearing

This article was originally published in the Journal of Tax Practice and Procedure, December 2018 – January 2019 edition. A. Introduction One of the most important rights a taxpayer has during the Internal Revenue Service (“IRS”) administrative collection process is to be notified of their right to a collection due process hearing before the IRS…

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ALERT: New Wave of Maryland Tax Audits Appears to Target Restaurants and Caterers

As Marylanders prepare for warmer weather, the Maryland Comptroller’s Office is targeting caterers and restaurants for what appears to be an industry-wide tax audit initiative. At the start, the audits appear to be a routine examination focused on four different areas of a taxpayer’s business: Assets; Expenses; Sales; Reconciliation of Tax Remittances. Generally, the auditor…

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In the Crosshairs: IRS Stepping Up Enforcement of Employment Taxes

Federal employment taxes amount to over one-third of all revenue collected by the Internal Revenue Service (IRS).  Therefore, it is no surprise that the IRS has recently increased enforcement actions against employers that fail to withhold employment taxes from its employees and remit those taxes to the federal government. Employers with outstanding employment taxes are…

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Nevada Woman Indicted For Evading Payment of Penalties Related to Employment Taxes

On November 16th, the U.S. Department of Justice charged a Nevada woman for attempted tax evasion related to employment taxes.  This recent indictment is just another sign that the Department of Justice is actively pursuing employment tax cases.  See “Business Taxpayer Update – 3 Things Employers Should Know About Employment Taxes, April 20, 2016.  According…

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Business Taxpayer Update – 3 Things Employers Should Know About Employment Taxes

If your business owes delinquent employment taxes, you could be subject to personal liability and you could go to prison. 1. The federal government is searching for you with increased enthusiasm There are indications that the federal government has renewed interest in pursuing employment tax enforcement.  For example, on December 8, 2015, the Internal Revenue Service…

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