Tax Warrior Chronicles

Offer In Compromise – Working With Your Tax Advisor

Posted on Thu, Mar 14, 2019

ANA GIOMBETTI - OFFICIAL 2018-1By: Ana Giombetti, CPA, JD


If the IRS is after you to collect a tax liability that is beyond your capacity to pay, you should be aware of a technique that may allow you to settle your tax debt for less than the full amount you owe. It's called an Offer in Compromise.

Like any creditor, IRS prefers a partial payment to no payment at all. Thus, IRS is sometimes willing to settle a tax ... Read More

New Partnership K-1 Disclosure Requirement - The IRS's Threat and Partial Retreat… We Mean Relief!

Posted on Fri, Mar 08, 2019

CHRIS CATARINO - OFFICIAL - 2016By: Chris Catarino, CPA, MT and Joseph Criscuolo, CPA


Buried in the 2018 instructions to Form 1065, U.S. Return of Partnership Income, is a new reporting requirement with a whopping noncompliance penalty. The blow-back from practitioners on this sneaky new disclosure was so great the IRS issued penalty relief provisions this week… here's the ... Read More

5 Tax Tips for Startups

Posted on Thu, Mar 07, 2019

By: Mark Sobel, CPA, JD, LLM 


Mark-SobelAs trusted advisors, we are asked by entrepreneurs to consult with them on the myriad of tax issues related to the startup phase of a new business enterprise.  Before we discuss any tax issues, it is imperative that resources and time are dedicated to understanding how the business will operate.  Questions to be asked are:  “what kind of goods or services will be provided?”, “what is the anticipated market ... Read More

Entity Structure Differences and Why It Matters

Posted on Wed, Mar 06, 2019

Brunell1By: Joseph Brunell, CPA


The Tax Cuts and Jobs Act of 2017 (“TCJA”) made one of the most important decisions when starting a new business--choosing an  entity type, even more important.  The tax considerations associated with the type of entity chosen now has greater consequences under the TCJA and should be explored in greater detail.  Here, we will look at the differences in the two main categories of entity structures.

... Read More

GILTI Formulas and Election to Individual Taxpayers for GILTI Relief

Posted on Fri, Mar 01, 2019

international_filing_requirements_2By: Yi Yang, CPA, MBA


Under the newly enacted Section 951A, beginning in tax year 2018, each U.S. shareholder of a controlled foreign corporation (CFC) is subject to current U.S. income tax on their share of global intangible low-taxed income (GILTI).  GILTI is defined as the excess (if any) of a U.S. shareholder’s net CFC-tested income over their net deemed tangible income return (NDTIR).  In September 2018, ... Read More

Estimated Tax Underpayments – Not Light Stuff Anymore

Posted on Mon, Feb 25, 2019

STEPHANIE OTAKE - OFFICIAL - 2017-1By: Stephanie Otake, CPA


Since 2016, the penalty for estimated tax underpayments has steadily increased. The rate has doubled since 2015 after years of not changing at all. Taxpayers should pay close attention to this trend. It should no longer be taken lightly or ignored, and here’s why.


Today, we focus on the rising penalty associated with underpaying ... Read More

Non-Resident Alien Withholding – Part II

Posted on Wed, Feb 20, 2019

International-ServicesBy: Patrick J. McCormick, J.D., LL.M. and Michael Rock, CPA


Welcome to Part II of our Non-Resident Alien Withholding blog. Today, we’ll look at the consequences of failing to withhold (or incorrectly withholding) on nonresident alien taxes.


As detailed in Read More

Non-Resident Alien Withholding: Part I

Posted on Thu, Feb 14, 2019

D&S Marketing_023-1By: Patrick McCormick, J.D., LL.M. and Michael Rock, CPA


Complying with domestic U.S. tax law can be tough; when foreign taxpayers are brought into the mix, the complexity can become overwhelming. In today’s global society, U.S. taxpayers (both businesses and individuals) are engaging in transactions with nonresident aliens more than ever. In part one of ... Read More

WEBINAR - The Experts Discuss Qualified Opportunity Zones

Posted on Mon, Feb 11, 2019

DS Webinar SeriesBuried within the Tax Cuts and Jobs Act of 2017 are six pages that create a massive tax-savings opportunity. Sections 1400Z-1 and 1400Z-2 define a completely new tax incentive for Qualified Opportunity Zones and Qualified Opportunity Funds. In short, individuals with capital gains obtain tax benefits by investing those gains in Qualified Opportunity Funds, which, in turn, invest in economically distressed areas designated as Opportunity Zones.


It’s a hot topic, and although recent ... Read More

Tax Wars, Episode III: Revenge of the Business Interest Expense Limitation

Posted on Tue, Feb 05, 2019

DSMarketing024-1By: Jeremy Ferman, CPA, MAcc


Last year, we discussed Internal Revenue Code §163(j) created by the Tax Cuts and Jobs Act of 2017 ("TCJA").  At the time, we knew business interest expenses were limited to 30% of Adjusted Taxable Income  + business interest income + floor plan financing interest expense.  We also knew businesses with gross receipts of $25 million or less were "excepted" from the limitation and that ... Read More