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Are you a U.S. person for living overseas who is required to file U.S. taxes? Then you should be especially aware of U.S. filing deadlines, and the importance of timely filing your tax return under IRC Section 7502. Filing a tax return is often stressful enough for most people living in the U.S. Filing a […]
Under the IRS “Subpart F” rules (26 USC Part III, Subpart F), certain categories of income of controlled foreign corporations (“CFCs”) must be included in the gross income of specified U.S. shareholders, even though the income may not have been distributed. In this article, we will explain the basics of Subpart F income. It is […]
Do you own or work for a closely-held corporation? Do you make frequent payments between your small C corporation and your shareholders? Then you should be especially careful about the constructive dividend rules. Under these rules, the IRS can deem certain payments made to or on behalf of its shareholders as dividends, even though they […]
Because partnerships have many different features from corporations, a question is frequently asked concerning partnerships: when do they officially end? While corporations theoretically have an indefinite life and identifying the closure of a corporation may sometimes be regarded as relatively easy, it may not always be as apparent when a partnership has terminated. This article […]
Have your tax returns been subject to an IRS audit? You should be aware that IRS procedures may allow you to contest the findings through IRS Audit Reconsideration, provided that you meet certain requirements. If the amount is significant or you believe that the IRS was erroneous in its determination, you contact Sherayzen Law Office, […]