How to defend executive compensation deductions (Section 162(m)) in a US tax dispute?
💼To defend executive compensation deductions under Section 162(m) in a US tax dispute, a publicly held corporation generally must prove the executive is not a “Covered Employee” or that the…
by catalog.lawyerMar 23 No commentsHow to avoid the US Accumulated Earnings Tax on corporate retained earnings?
💡The US Accumulated Earnings Tax is a strict federal penalty of 20% imposed on C corporations that stockpile cash beyond the standard $250,000 safe harbor limit instead of distributing dividends.…
by catalog.lawyerMar 23 No commentsWhat are the US tax requirements for liquidating a C corporation?
🚨Liquidating a US C corporation typically triggers double taxation under Sections 331 and 336 of the Internal Revenue Code. The corporation must generally file Form 966 within 30 days of…
by catalog.lawyerMar 23 No commentsWhat to do if the US IRS challenges your corporate research and development (R&D) tax credits?
💡If the US IRS challenges your corporate R&D tax credits, you must successfully prove that your business activities pass the strict federal “Four-Part Test.” You are generally required to provide…
by catalog.lawyerMar 23 No commentsHow to document intercompany transactions to pass a US IRS transfer pricing audit?
💡To pass a US IRS transfer pricing audit, a company generally needs to prove that its intercompany transactions follow the Arm’s Length Principle under Section 482 of the Internal Revenue…
by catalog.lawyerMar 23 No commentsHow to resolve a US IRS dispute over worker classification (employee vs contractor)?
💼To successfully resolve a US IRS dispute over worker classification, you generally must prove that your business lacks behavioral and financial control over the independent contractor. If you voluntarily realize…
by catalog.lawyerMar 23 No commentsHow to appeal a US IRS Trust Fund Recovery Penalty against corporate officers?
💡If you receive Letter 1153 proposing a US IRS Trust Fund Recovery Penalty (TFRP), you generally have exactly 60 days to file a formal written protest. This severe penalty makes…
by catalog.lawyerMar 23 No commentsHow to manage a US IRS Large Business and International (LB&I) Division audit?
💡Managing an IRS Large Business and International (LB&I) audit requires strict adherence to federal deadlines. Corporations generally must respond to formal Information Document Requests (IDRs) within 15 to 30 days.…
by catalog.lawyerMar 23 No commentsHow long does it take to obtain a Private Letter Ruling (PLR) from the US IRS?
💡Obtaining a Private Letter Ruling (PLR) from the US IRS generally takes between 6 to 12 months from the date of submission. As of March 2026, the standard IRS user…
by catalog.lawyerMar 23 No commentsHow to structure a tax-free corporate reorganization under US Section 368?
💼To qualify for a tax-free reorganization under Section 368 of the US Internal Revenue Code, a transaction must generally have a valid Business Purpose, maintain a Continuity of Interest (COI),…
by catalog.lawyerMar 23 No commentsHow much does a US transfer pricing study cost for multinational corporations?
💡Generally, a comprehensive US transfer pricing study costs between $15,000 and $50,000+ depending on the complexity of your multinational operations. Hiring a Big 4 accounting firm often pushes the price…
by catalog.lawyerMar 23 No commentsHow long does the US IRS have to assess additional corporate tax (Section 6501)?
💡Under Internal Revenue Code Section 6501, the standard statute of limitations for the US IRS to audit and assess additional corporate tax is exactly 3 years from the date the…
by catalog.lawyerMar 23 No commentsHow to dispute an FBAR penalty assessment in a US federal district court?
🔍To dispute an FBAR penalty assessment in a US federal district court, you generally cannot file a petition in the US Tax Court. Instead, most applicants must either wait for…
by catalog.lawyerMar 23 No commentsHow much are the US IRS penalties for late filing of a corporate tax return (Form 1120)?
💼The US IRS penalties for late filing of a corporate tax return (Form 1120) generally equal 5% of the unpaid tax for each month the return is late, capping at…
by catalog.lawyerMar 23 No commentsWhat to do if a foreign bank closes your account because you are a US citizen?
🚨If a foreign bank closes your account due to FATCA regulations, you generally have 30 to 60 days to secure your funds. You must still report the account’s historical maximum…
by catalog.lawyerMar 23 No commentsHow to prove reasonable cause for late US FBAR filing to avoid penalties?
💡To avoid severe penalties for filing a late US FBAR (FinCEN Form 114), you must generally submit a “Reasonable Cause” memorandum. This document must prove that your failure to file…
by catalog.lawyerMar 23 No commentsHow to report signature authority over employer foreign accounts on a US FBAR?
💡If you have signature authority over your employer’s foreign financial accounts and the aggregate value exceeds $10,000 at any time during the year, you generally must file an FBAR. The…
by catalog.lawyerMar 23 No commentsWhat to do if the US IRS sends you a Letter 3115 regarding missing FBARs?
📩If you receive an IRS Letter 3115 (or a similar FATCA mismatch notice) regarding missing FBARs, it generally means a foreign bank reported your account to the US government, but…
by catalog.lawyerMar 23 No commentsHow to release a US IRS federal tax lien after completing a settlement?
💡Once your federal tax debt is fully paid or legally settled, the US IRS is mandated by law to issue a Certificate of Release of Federal Tax Lien within 30…
by catalog.lawyerMar 23 No commentsHow to use a US bankruptcy to discharge old IRS tax debts instead of a settlement?
💡Under the federal “3-2-240 rule,” you can generally discharge old US IRS income tax debts through Chapter 7 bankruptcy if the tax return was originally due at least 3 years…
by catalog.lawyerMar 23 No commentsHow to report foreign life insurance and mutual funds on a US FBAR?
📄To know how to report foreign life insurance and mutual funds on a US FBAR, you must calculate their total value. Foreign life insurance with a cash surrender value and…
by catalog.lawyerMar 23 No comments
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