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The consequences for failing to do so can be costly.

IRS LT11 Notices ("LT11") and Letters 1058 are no laughing matter. The IRS issues these particular "final" notices to taxpayers before it takes certain levy actions.

In the international tax context, the source of a taxpayer's income can have significant implications.

On June 7, 2022, a bill was introduced in the U.S. Senate that would provide greater clarity regarding the taxation and regulation of digital assets. Here are some of highlights.

Issue: Under Texas law, are Sirius XM's monthly subscription fees from Texas users are receipts from a "service performed in this state"?

The 2021 Texas Legislature made significant changes to statutory provisions governing Series Limited Liability Companies. Largely, they make Texas law governing Series LLCs more consistent with ...

Section 6751(b) of the Code has been a potent weapon for taxpayers since the Second Circuit held in Chai that certain penalties are not valid without written managerial approval.

The term "accredited investor" is frequently heard in the field of financial investing. But many investors lack an in-depth understanding of the implications of accredited investor status or how it is acquired...

Taxpayers have long utilized trust arrangements for the transfer of wealth to beneficiaries or for the protection of assets from creditors.

Section 367(a) of the Internal Revenue Code governs the outbound transfer of property by a U.S. person to a foreign corporation in certain non-recognition transactions.

Are you U.S. citizen or resident? Have you ever just wanted to leave the whole U.S. federal tax system behind? Well, you can . . . try at least. But there's a cost.

In Moore v. United States, the U.S. Ninth Circuit Court of Appeals recently rejected arguments that the mandatory repatriation tax imposed under section 965 of the Internal Revenue Code violated the...

The term "NRA withholding" is not a reference to deductions from a person's paycheck to support the National Rifle Association. Instead, it is a general term that refers to federal tax withholdings...

An organization may meet the requirements of section 501(c)(3) although it operates a trade or business as a substantial part of its activities, if the operation of such trade or business is in furtherance...

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

This 28-page opinion regards Petitioners Robert Lewis Starer and Merle Ann Starer (the "Starers"), controlling shareholders of the Bayview Corp. (Bayview), an S corporation. Bayview operated...

Hiya folks, and welcome back to another Texas Tax Roundup! March 2023 brought us a lot of administrative action, especially for Texas sales or use tax. Let's get started!