Resources

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...

The IRS continues to struggle with processing and adjudicating ERC claims. Earlier today, Taxpayer Advocate published a Blog post with an update on the IRS’ progress (or lack thereof) and a call to the IRS to bring much...

Once administrative prerequisites are satisfied—namely payment of the liability, the filing of a valid refund claim, and the passage of requisite time—a taxpayer may initiate a refund lawsuit. But where and how that...