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On November 21, 2011, the Minnesota Court of Appeals ruled in favor of Helpful Hands Transportation, Inc. (HHT) – the client of Sherayzen Law Office – and reversed the unemployment law judge’s (ULJ) determination that HHT’s workers should be classified as employees. Judge Kalitowski wrote the opinion. Two respondents were listed as “pro se”, but […]
As discussed in an earlier article, Form 8938 is used by specified individuals to report the ownership of specified foreign financial assets if the total value of those assets exceeds an applicable threshold amount. Similarly to most international tax forms issued by the IRS, Form 8938 has its own system of penalties. What makes Form […]
In November of 2011, the U.S. Department of the Treasury issued a new version of Form TD F 90-22.1, now known as FinCen Form 114 commonly known as FBAR. All filers must now use this form in order to report their foreign bank and financial accounts. The main difference between the previous (March 2011) version […]
The tax effects to shareholders of liquidating a corporation are largely governed by IRC Sections 331, 332 (liquidations of subsidiaries) and 338 (dealing with certain stock purchases treated as asset acquisitions). This article will examine only the general tax rule found in Section 331 (keep in mind that there are numerous exceptions and variations depending […]
In an earlier article, I discussed in general that the IRS imposed a new tax reporting requirement on individual taxpayers who hold specified foreign financial assets with an aggregate value exceeding a relevant threshold. Such taxpayers will need to report those assets on the new IRS Form 8938, which must be attached to the taxpayer’s […]