green sklarz llc: When Do Payroll Tax Debts Become Criminal?
- 04/21/24 07:48 AM
Recently, the IRS and United States Department of Justice (“DOJ”) have been criminally prosecuting more payroll tax cases than ever before. Several years ago the decision was made to focus on payroll tax cases for both civil and criminal enforcement, given the importance of payroll taxes to the federal income stream.
When it comes to charging taxpayers criminally for the failure to account and pay over payroll taxes there are three main statutes the IRS and DOJ use: IRC § 7202 (the felony statute for payroll tax violations), IRC § 7215 (the misdemeanor statute for payroll violations) and IRC § 7201 (Tax … (1 comments)
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green sklarz llc: IRS Enforcement Options For Payroll Tax Debts: A Comprehensive Review
- 04/21/24 07:35 AM
Businesses that fall behind with payroll taxes are the number one source of new clients for most tax rep professionals. The IRS takes payroll tax debts very seriously, as it is a double whammy on the government: it does not receive the tax money, and yet it will be issuing refunds to the taxpaying employees when they file their 1040 tax returns.
So the IRS has a letter it sends to employers, Letter 903, that outlines the number of enforcement actions that may occur if the employer does not change course and pay the taxes. These include any and all of the … (0 comments)
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green sklarz llc: The First Step to Resolving a Payroll Tax Debt? Compliance!
- 04/21/24 07:16 AM
Businesses that fall behind with payroll taxes are the number one source of new clients for most tax rep professionals. The major issue many of these clients has is confusion about what to do first. Often we hear “I should make a payment against the oldest period first, that way the IRS knows we are serious.”
No they don’t!
The IRS does not think that way. The first step to do anything with the IRS is to get into tax compliance first.
What is “Tax Compliance”?
In order for the business to have any chance of surviving the tax debt issue is being able to … (1 comments)
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green sklarz llc: What To Do If You Cannot Pay the Payroll Taxes?
- 04/21/24 06:48 AM
Businesses that fall behind with payroll taxes are the number one source of new clients for most tax rep professionals. The first three issues that must be dealt with are:
Can the business get into and maintain tax compliance? Is this business viable in its current form? If the business is not viable in its current form, can it be restructured to be a viable ongoing concern? Tax Compliance
In order for the business to have any chance of surviving the tax debt issue is being able to get back into tax compliance, meaning it is filing and paying the payroll taxes … (1 comments)
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green sklarz llc: Challenging a Bad Tax Assessment at the Collection Due Process Hearing
- 04/21/24 05:40 AM
We frequently have taxpayers arrive in our office with collection notices for an IRS balance due that they believe they do not owe. Whether due to not receiving the notice of proposed changes (CP-2000), or because they submitted records that were ignored by the IRS, these taxpayers are now facing balances with penalty and interest they should not have to pay.
More often than not it is the Final Notice of Intent to Levy and Your Right to a Hearing (CP-90) that gets them to act and contact us. Other times it is the Notice of Federal Tax Lien being filed that … (1 comments)
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green sklarz llc: IRS Enforcement Update with the Director of IRS Collection Policy
- 03/23/24 05:02 AM
Joining me, Eric Green, on this week's Tax Rep Network Podcast is the Director of IRS Collection Policy, Rocco Steco, to update everyone on where the IRS is right now in terms of turning back on the automated enforcement and what we and our clients can expect in the coming year.
You can watch the video on YouTube here: https://www.youtube.com/watch?v=OWGerNZLAY8
You can listen to the Tax Rep Network Podcast on all podcasting channels.
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green sklarz llc: New Haven, CT: What is Reasonable Compensation for an S Corp Owner?
- 03/10/24 06:53 AM
I am a tax attorney in New Haven, Connecticut that help taxpayers dealing with IRS audits and back balances all over the country. For S Corporation owners having a grasp and making the right call on compensation is not just smart business practice—it's a vital part of following IRS rules. Reasonable compensation ensures that shareholder employees are fairly paid for their efforts while steering clear of tax complications. In this piece we'll delve into what reasonable compensation involves, its importance and how S Corporation owners can smoothly navigate IRS guidelines.
Reasonable compensation as defined by the IRS refers to the pay that … (1 comments)
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green sklarz llc: New Haven, CT: The IRS Crackdown on Non-Filers: What You Need to Know
- 03/09/24 05:20 AM
I represent taxpayers with tax issues in New Haven, Connecticut as well as all over the country before the IRS, Department of Justice Tax Division and State Departments of Revenue. The IRS knows there are more than 10 million non-filers and has known who they are for several years now. Last week the IRS announced the long awaited move against the top 125,000 high-income non-filers is starting.
For those who haven't filed their taxes there are a few initial considerations:
How many years must they file? Should they just file or should they request Voluntary Disclosure? Compliance with tax regulations goes beyond … (0 comments)
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green sklarz llc: How to Settle a Tax Debt, Part 3: Uncollectible Status
- 03/02/24 03:33 AM
I am a tax attorney in New Haven, Connecticut that helps taxpayers struggling with tax debt all over the country. Dealing with tax matters can feel overwhelming, for any taxpayer. Whether its dealing with mounting debts or the looming threat of IRS enforcement actions the financial strain can be quite daunting. Fortunately there are options to help individuals facing challenges one being the option to acquire Uncollectible Status, also known as Currently Not Collectible (CNC) status from the IRS.
Uncollectible status offers a relief for taxpayers experiencing hardship and unable to fulfill their tax obligations. When granted status the IRS puts a … (3 comments)
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green sklarz llc: How to Settle a Tax Debt, Part 2: Installment Agreements
- 02/29/24 03:20 AM
I am a tax attorney in New Haven, Connecticut that helps taxpayers struggling with tax debt all over the country. Facing a tax debt can be a daunting experience, but the IRS offers options for taxpayers to manage their obligations through installment agreements. However, these agreements come with their own set of rules and considerations that taxpayers and practitioners must understand to navigate effectively.
An installment agreement is essentially a structured payment plan between the IRS and a taxpayer to settle back taxes over a period of time, typically in monthly installments. While it offers relief by spreading out the payments, there … (3 comments)
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green sklarz llc: How to Settle a Tax Debt, Part 1: Offers-in-Compromise
- 02/27/24 05:21 PM
I am a tax attorney in New Haven, Connecticut that helps taxpayers struggling with tax debt all over the country. If you are feeling overwhelmed by mounting tax obligations, you're not alone. Luckily there's a solution that could ease your burden; the IRS Offer in Compromise (OIC) program. This program offers hope to those facing hardship by providing a way to settle tax liabilities for less than the amount owed. In this article we'll take a look at the IRS OIC program discussing its eligibility requirements, application process and important factors to consider.
The IRS OIC program is designed for taxpayers who … (0 comments)
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green sklarz llc: Navigating IRS Innocent Spouse Relief: Understanding Your Options
- 02/22/24 12:27 PM
The focus of my practice is civil and criminal tax representation, including helping taxpayers seek innocent spouse relief from the IRS.
Navigating the complexities of tax law can be a daunting task, especially when it comes to joint tax returns and the potential liabilities they entail. Married taxpayers who file jointly with their spouses often find themselves in situations where they are unfairly held responsible for tax liabilities that they believe should not be their burden to bear. However, relief may be available through the IRS Innocent Spouse Relief provisions outlined in Internal Revenue Code (IRC) Section 6015.
When considering Innocent Spouse Relief, … (0 comments)
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green sklarz llc: Bloomberg Tax: Non-Filer? How to Come in From the Cold With the IRS
- 08/19/22 07:21 AM
My latest column is out on Bloomberg Tax: Are You a Non-Filer? How to Come in From the Cold With the IRS
In it I walk you through whether the tax returns can just be filed, how many years to file, and when the taxpayer should consider making a voluntary disclosure with the IRS.
Check out the column here and let me know if you have any questions or comments: https://news.bloombergtax.com/tax-insights-and-commentary/are-you-a-non-filer-how-to-come-in-from-the-cold-with-the-irs
Thanks, Eric
Eric L. Green, JD, LL.M.
Green & Sklarz LLC
1 Audubon Street, 3rd Fl
New Haven, CT 06511
egreen@gs-lawfirm.com
https://gs-lawfirm.com
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green sklarz llc: My Bloomberg Column: Unpaid Payroll Taxes Just Became More Dangerous
- 07/08/22 08:28 AM
My most recent column on the new enforcement focus on unpaid payroll taxes is out on Bloomberg Tax:
https://news.bloombergtax.com/tax-insights-and-commentary/unpaid-payroll-taxes-just-became-more-dangerous-for-owners
If you or your client has a payroll tax problem please contact me at either (203) 285-8545 or by email at egreen@gs-lawfirm.com.
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green sklarz llc: Tax Rep & UConn Launch of the IRS Representation Certificate Program
- 10/19/21 03:52 PM
Thrilled to announce that TAX REP LLC, in partnership with UConn School of Business is launching the IRS Representation Certificate Program this Friday the 22nd!
This program includes five, four-hour modules for a total of 20 hours of learning.
They are:
IRS Collections Offers-in-Compromise Audits Resolving Payroll Tax Cases Innocent Spouse Access to the self-paced course begins on Friday, October 22 and is available through Wednesday, December 22.
Check out more on the program here: https://online.uconn.edu/irs-certificate-program/...
Included in each of the modules are exhibits to help you understand the processes addressed and familiarize you with IRS forms and correspondence. This will allow you to evaluate … (1 comments)
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green sklarz llc: Tax Rep Podcast: When The IRS Wants the Quickbooks File
- 10/07/21 03:07 AM
Joining Eric on this week's Tax Rep Network Podcast is Walter Pagano. Walter is a partner and tax controversy leader at Eisner Advisory Group in New York where he specializes in forensic accounting and controversy issues. Walter and Eric discuss why the IRS wants the Quickbooks, file, the rules around their ability to obtain it, and what practitioners should be doing before and during the exam.
Check out the podcast episode on Spotify, ITunes, Apple Podcasts, Google Podcasts, or on our podcast page here: https://taxrepllc.com/subscribe-tax-rep-network-podcast/
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green sklarz llc: IRS Automated Enforcement is Back in Full-Swing!
- 08/23/21 01:13 PM
Today's mail....come on Tax Rep Members...its time to save taxpayers and add $100,000 to your 2021 bottom line!
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green sklarz llc: IRS Tax Compliance: What is Tax Compliance and Why Is It Important?
- 08/12/21 04:04 AM
I spend much of my day resolving taxpayer issues with the IRS. And though everyone wants to focus on the cool stuff - making massive debts vanish for pennies on the dollar - it actually all starts with "Tax Compliance."
So what is Tax Compliance you may be asking...good question!
Tax Compliance means that the taxpayer has filed all returns due and owing as of this moment (yes you non-filers!), defined as the last 6 years, and is making their current tax period payments. So as I sit here in August 2021, Tax Compliance would nean having 2015 - 2020 filed (if the … (2 comments)
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green sklarz llc: Podcast: IRS Voluntary Disclosure - Where Are We Now
- 06/11/21 03:44 AM
I bet you didn’t know that I (Eric Green) am on the subcommittee for the ABA tax section’s Criminal Tax committee? Well on this week's podcast I am joined by my committee members Laura Gavioli and John Nail to update everyone on where the IRS stands on voluntary disclosure for both domestic and foreign issues, and how best to make use of the program to save your client from their past misdeeds.
Check out this podcast episode as well as all 102 others on Spotify, Apple Podcasts, ITunes, Google Podcasts or the podcast page here: https://taxrepllc.com/subscribe-tax-rep-network-podcast/
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green sklarz llc: IRS Enforcement Update for the Tax Answers Advisor Podcast
- 05/03/21 06:20 AM
I was thrilled to join Marcelino Dodge on his Tax Answers Advisor Podcast this week to discuss where IRS Enforcement is headed in 2021 and beyond.
You can catch the edpisode here: https://www.voiceamerica.com/episode/130731/irs-collections-and-enforcement-how-to-solve-unpaid-tax-issues
Episode DescriptionWe have all heard the commercials asking, “Do you owe $10,000 or more to the IRS?” Or, you may wonder “What is the IRS really doing with collections and enforcement?” Though it may be calm now, taxpayers who have unpaid taxes or who are non-filers will soon be in for a big awakening. Eric Green of the Tax Rep Network and managing partner in the law firm Green & … (0 comments)
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Recently, the IRS and United States Department of Justice (“DOJ”) have been criminally prosecuting more payroll tax cases than ever before. Several years ago the decision was made to focus on payroll tax cases for both civil and criminal enforcement, given the importance of payroll taxes to the federal income stream.
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