Resources

Grantor trusts are treated differently from other trusts for federal income tax purposes. Whereas many trusts are respected as separate entities for tax purposes, grantor trusts are disregarded with the grantor (or deemed...

This blog builds on prior posts concerning refund litigation. This blog explores the types of tax refund cases that can be brought in the U.S. district courts and the U.S. Court of Federal Claims. Types of Refund Litigation...

The application of U.S. tax laws often turns on the meaning of “residency.” Although U.S. citizens and residents are subject to federal income taxes on their worldwide income, non-residents who are not U.S. citizens...

Introduction Most federal tax disputes are resolved administratively or in the United States Tax Court, where taxpayers might challenge IRS determinations in a specialized forum that requires no prepayment of the disputed...

There are more than 100 penalties in the Internal Revenue Code. Each penalty varies in scope, but a common defense for almost all of them is “reasonable cause.” Where this defense applies, the IRS can’t impose...