This may be surprising to you but a levy on your Social Security payments does not necessarily stop after the statute of limitations on the collection of tax expires. Yes, collection action after the statute of limitations expires must stop and tax liens must be released. But, as… Read More

The National Taxpayer Advocate (NTA) has identified a serious IRS problem in calculating Collection Statute Expiration Dates or CSEDs. Generally, under IRC § 6502, the IRS has 10 years to collect a liability from the date of assessment. After this 10-year period or statute of limitations has expired,… Read More

Those moving to Puerto Rico to avail themselves of the tremendous tax benefits of Puerto Rico Act 22 (now Act 60) are all too familiar with the bona fide residency test. In preparation for an IRS residency audit, they know the three prevailing tests: the Physical Presence Test,… Read More

On May 28, 2021, the Treasury Department published its General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals, or “Green Book”, which details the Biden Administration’s tax-related proposals, including those with respect to cryptocurrency. In it, it proposes new information-reporting requirements for tax years beginning after December… Read More

If your Non-Profit Charter has been revoked by the IRS, you have several options for reinstatement depending upon how soon you engage the IRS to correct the problem. For non-profit organizations who seek reinstatement within 15 months of revocation, they may participle in retroactive “streamlined” procedures where penalties… Read More

IRS seeks $32 million for crypto tax enforcement. It seeks $32 million ($3 million on IT specialist compensation, $6 million on hardware and software and $23 million on contractual services) to enhance cryptocurrency-related enforcement efforts. The funding will enable the IRS’s Criminal Investigation Division (CID) to: expand the… Read More