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Closing agreements constitute an important part of tax representation and tax planning. A “closing agreement” is a final agreement between the IRS and the taxpayer on a specific issue or liability. Closing agreements are entered into pursuant to IRC Section 7121. Usually, closing agreements may be entered into when it is beneficial to permanently and […]
Understanding how to cite Treasury Regulations is crucial to being able to find the regulations relevant to a tax case. This is why I devote this brief essay to explaining the location and basics of citation of Treasury Regulations. Treasury Regulations are located in Title 26 of the Code of Federal Regulations (“C.F.R.”). This corresponds […]
In previous article, I discussed what type of information you should bring to your Minneapolis business attorney. In this essay, I shift the focus toward the second part of the preparation which is about what type of questions you need to ask your business lawyer. Usually, the questions that you want your Minneapolis business lawyer […]
Preparing for the initial consultation with your Minneapolis business lawyer usually involves at least two steps. First, gathering the information you need to supply to your business attorney. Second, preparing the questions you want to ask your business lawyer. This essay deals with the first part of the preparation. It is important to understand that […]
Although there is a general misconception that U.S. citizens can relinquish their citizenship in order to escape high U.S. taxes, most of the time this is not true. If you are contemplating such a move, it is essential to understand the basic rules relating to expatriation for purposes of tax avoidance, as the taxes and […]