All entries by this author

Form W-2 Penalties

Feb 19th, 2012 | By | Category: Legal Notes, Tax Lawyers Minneapolis

A W-2 is required to be filed by every employer who is engaged in a trade or business paying remuneration (including noncash payments) of $600 or more for a year in which services are performed by an employee.  A W-2 must be filed for each employee for whom income, Social Security, or Medicare tax was [...]

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IRS Classification of Foreign Entities: “Per Se” Foreign Corporations

Feb 12th, 2012 | By | Category: international tax lawyer minnesota, Legal Notes

For the U.S. tax compliance purposes, it is very important to properly classify foreign business entities, because there are special IRS requirements associated with ownership of foreign business entities. For instance, a list of various tax forms is tied to particular classification (for example, certain U.S. taxpayers are required to file Form 5471 with respect [...]

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Will You be Subject to the AMT in the Tax Year 2012?

Feb 11th, 2012 | By | Category: Legal Notes, tax lawyers minnesota

The Alternative Minimum Tax (AMT) is an additional tax that certain individuals must pay on top of their regular tax liability.  When the original “minimum tax” was enacted in 1969, its purpose was to limit the ability of high-income earners from paying little or no tax by using certain tax breaks.  Tax breaks that may [...]

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Form 941 Penalties

Feb 9th, 2012 | By | Category: Legal Notes, Tax Lawyers Minneapolis

In a previous article, we covered some of the basics of Form 941. In this article, we will explore some of the major penalties that may apply for failure to comply with the requirements of Form 941. These penalties may be severe and, in certain circumstances, may even lead to criminal charges. Failure to File [...]

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Treasury and the IRS Issue Proposed Regulations for FATCA Implementation

Feb 8th, 2012 | By | Category: Legal Notes, voluntary disclosure lawyers Minneapolis

On February 8, 2012, the U.S. Treasury Department and the Internal Revenue Service issued proposed regulations for the next major phase of implementing the Foreign Account Tax Compliance Act (FATCA). FATCA and FFI Reporting under Proposed Regulations FATCA was enacted by the U.S. Congress in 2010 as part the Hiring Incentives to Restore Employment (HIRE) [...]

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CPT (Carriage Paid To)

Feb 7th, 2012 | By | Category: international contract lawyer minneapolis, Legal Notes

The purpose of this article is provide a general background to one of the most important terms in international contract drafting, Incoterms 2010 CPT. General Provisions of CPT CPT (Carriage Paid To) means that the seller delivers the goods to the carrier of another person nominated by the seller at an agreed place and that [...]

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Taxation of Oil & Gas Royalty Interests

Feb 6th, 2012 | By | Category: Legal Notes, Tax Lawyers Minneapolis

The recent oil boom in regions such as the Bakken Oil Field has created millionaires overnight based upon royalty interests in oil and gas leases of investors. While fortunes can be made from such payments, it is important to understand that there may be various potential risks involved, as well as numerous taxes. This article [...]

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Criminal Tax Evasion

Feb 5th, 2012 | By | Category: Legal Notes, tax litigation lawyers Minneapolis

This article provides some general background to IRC Section 7201 criminal tax evasion charges and describes Section 7201 principal criminal penalties.   As you will see, the penalties are severe, and you should immediately seek the advice of a tax attorney if you have any doubts as to whether you are complying with the law [...]

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Form 941 Filing Requirements

Feb 4th, 2012 | By | Category: Legal Notes, Tax Lawyers Minneapolis

With the Federal government searching for much-needed revenues, it is very likely that the IRS will be watching much more closely for unpaid payroll taxes, as it has been in recent years.  This article will explain the purpose of Form 941 and when it needs to be filed.  In a future article, we will cover [...]

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IRS Power to Reallocate Income, Deductions, and Other Items under IRC Section 482

Jan 30th, 2012 | By | Category: business tax attorney Minneapolis, Legal Notes

Some taxpayers may be tempted, especially in situations involving related parties, to arbitrarily shift the source of income or allocation of deductions, in order to avoid or lessen taxes.  Congress, however, enacted IRC Section 482 to give the IRS wide power to prevent such actions.  This article will give a brief overview of some aspects [...]

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