irs: 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)
irs: 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)
irs: 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)
irs: 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)
irs: 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)
irs: 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)
irs: 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)
irs: 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)
irs: 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)
irs: 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)
irs: 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 … (1 comments)
irs: 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. … (2 comments)
irs: Tax Rep Network Podcast: The Lifecycle of a Criminal Tax Case
- 02/10/22 05:34 AM
On this week’s podcast episode Eric is joined by Gwen Moore and Ajay Gupta to walk through how a criminal tax works, from referral to sentencing. Check out the podcast on ITunes, Google Podcasts, Apple Podcasts, Spotify or on our Podcast Page Here! Want to contact Gwen? She can be found here trying to save taxpayers. https://www.mooretaxlawgroup.com/attorney/moore-guinevere-m/ Ajay Gupta can be contacted here: https://www.mooretaxlawgroup.com/attorney/ajay-gupta/ Interested in joining Tax Rep Network and building an unbelievable Tax Rep practice? Come check out Tax Rep here! Want to check out a special offer from bench on outsourced bookkeeping and forensic reconstruction? https://bench.co/taxrep Use CallENQ to get through to the IRS in under 3 minutes! Special Offer … (0 comments)
irs: Tax Rep Network Podcast: Automate Everything! With Andrew Lassise
- 01/27/22 04:27 PM
Joining Eric on this week’s podcast is Andrew Lassise from the Tech4Accountants podcast, where they discuss how to actually make money by leveraging technology, streamlining your operation and scaling your enterprise so it’s no longer a ‘practice’ but a ‘business’ that you work on instead of in. Catch this and all the podcast episodes on ITunes, Google Podcasts, Apple Podcasts, Spotify, or on the Podcast Page.
Want to connect with Andrew? Check out https://tech4accountants.net Interested in joining Tax Rep Network and building an unbelievable Tax Rep practice? Come check out Tax Rep here! Want to check out a special offer from bench on outsourced … (0 comments)
irs: Non-Filers: The Forensic Reconstruction Workshop January 13th
- 01/05/22 07:21 AM
Taxes are at the heart of our economic engine. Though we have a “voluntary tax system”, it’s not THAT voluntary! The IRS makes a point of pursuing taxpayers who fail to uphold their end of the bargain, and is currently pursuing the more than 10 million non-filers, many of whom are high-income earning. Ready to make more money and take your practice to the next level? This special workshop with Tax Attorney Eric Green (Tax Rep Network) and Forensic Accountant Dawn Brolin, CPA, CFE (Designated Motivator) will walk you through how to handle non-filers, help them pull together the many missing … (1 comments)
irs: The Insider's Guide to IRS Offers - Released in Time for Black Friday!
- 11/18/21 01:20 AM
I am thrilled the newest guide in our Tax Rep library, The Insider's Guide to IRS Offers, is now available for pre-sale (e-book release date is 12/1, printed books expected to ship 12/15)! Want to really understand IRS Offers-in-Compromise? Have you ever worked through them and wish someone could answer all your questions? Well here it is, the perfect guide to do just that! In this guide I pulled the top 100 questions from my popular workshops and answered them all. You may already be doing Offers-in-Compromise or just starting on your first case. This guide will walk you through the Offer-in-Compromise program, … (4 comments)
irs: Podcast: The IRS's International Enforcement Update with Jason Freeman
- 11/08/21 05:35 PM
Joining Eric on the Tax Rep Network podcast again is Jason Freeman from Freeman Law to discuss the current state of IRS Enforcement on foreign bank accounts and international form filings, what options taxpayers still have to resolve these issues, and what advice we should be giving clients today. Jason and Eric also discuss the upcoming International Tax Symposium being hosted by Freeman Law on November 18th and 19th. Catch Episode 113 with Eric & Jason here: https://taxrepllc.com/subscribe-tax-rep-network-podcast/ Want to check out the International Tax Symposium? https://internationaltaxsymposium.freemanlaw.com/ … (1 comments)
irs: Tax Rep Network Podcast: Its All My Fault
- 10/14/21 12:22 PM
On this week’s podcast Eric discusses the realization of what it is to take extreme ownership in your practice, what happens when you don’t, and how to turn things around. Eric quotes former navy seals Jocko Willink and talks about the espisode where Jocko joins Andy Stumpf on Andy's podcast Cleared Hot during the episode (Cleared Hot Episode 122). You can listen to the episode on Spotify, Google Podcasts, Apple Podcasts and ITunes, or at the Podcast Page here: https://taxrepllc.com/subscribe-tax-rep-network-podcast/ Looking for Jocko Willink's and Andy Stumpf's content? Here are the links to get the book and listen in on their material, which … (1 comments)
irs: 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/ … (2 comments)
News, updates and innovative discussion of what is happening in the world of estate planning, tax planning, and criminal and civil taxpayer representation.
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.
;)
;)
;)
