Tax Articles

A Primer on FIRPTA Withholding

At its most basic, any disposition of a U.S. real property interest by a foreign person (as transferor) is subject to the Foreign Investment in Real Property Act of 1980, more commonly known as FIRPTA.[1] So, when a foreign person or entity sells, transfers, or otherwise disposes of a piece of U.S. real property, the transferee will likely have to withhold a certain percentage of the sales price.[2] Defining Disposition The term disposition as used

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Tax Articles

The Streamlined Filing Compliance Procedures

In an increasingly common occurrence, a client calls in somewhat of a tizzy over foreign information returns, which, apparently, she was “required” to file for the past few years. She’s gone to three different CPAs, only the last one of which even asked her whether she had foreign assets or interests. Her new CPA, one of the good ones, inquired about any foreign relationships that she might have, and she disclosed a Swiss bank account,

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The Truth about Amending Tax Returns

Clients are untrustworthy.  As a tax controversy attorney, this is my experience. I have heard that other types of law deals with more honorable sorts, but I’ll believe it when I see it.  When a client comes to you and says “whoopsie, I forgot to report [insert absurdly large number

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Mathews v. Commissioner (T.C. Memo. 2021-85)

On July 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Mathews v. Commissioner (T.C. Memo. 2021-85). The primary issue presented in Mathews was whether the Tax Court had jurisdiction to hear a petitioner when the pro se petitioner filed his petition (sent a letter to

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Delgado v. Commissioner (T.C. Memo. 2021-84)

On July 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Delgado v. Commissioner (T.C. Memo. 2021-84). The primary issue presented in Delgado was whether the petitioner’s frivolous argument that he did not receive taxable income in 2017 because he was not engaged in a “trade

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Peterfreund v. Commissioner (T.C. Memo. 2021-83)

On July 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Peterfreund v. Commissioner (T.C. Memo. 2021-83). The primary issue presented in Peterfreund was whether the IRS’s Whistleblower Office (WBO) abused its discretion because it did not initiate an administrative or judicial action and it did

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Pragias v. Commissioner (T.C. Memo. 2021-82)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Pragias v. Commissioner (T.C. Memo. 2021-82). The primary issue presented in Pragias was whether the six-year statute of limitations under IRC § 6501(e) (substantial omission of items) applied. The Substantial Omission Extension under IRC §

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