New global interest netting provision cuts liability
Article Abstract:
The introduction of the IRS Restructuring and Relief Act of 1998 provides relief to taxpayers having problems with tax overpayments and underpayments. Since the implementation of the Tax Reform Act of 1986, taxpayers have been forced to pay higher interest rates on underpayments than the IRS has paid on tax overpayments. The IRS dealt with interest rate differentials only when there is reliable statutory authority and administrative convenience. It could not handle all cases where the differential had a adverse effect on taxpayers. The 1998 Act provides that the interest differential on overlapping periods of interest on income tax overpayments and underpayments shall be removed. It also sets a net interest rate of zero on equivalent amounts of overpayment and underpayment for any given period.
Publication Name: Practical Tax Strategies
Subject: Law
ISSN: 0040-0165
Year: 1999
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IRS collections are not put off by offshore asssets
Article Abstract:
The IRS's power to reach off-shore assets of persons attempting to evade U.S. taxation is the focus of this article. The author discusses the various avenues the IRS may legitimately use to collect taxes, the influence of treaties, and how expatriation is not the most efficient means of tax avoidance.
Publication Name: Practical Tax Strategies
Subject: Law
ISSN: 0040-0165
Year: 1999
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More becomes less when transferee liability attaches
Article Abstract:
The IRS's power to reach assets in cases of fraudulent conveyances is the focus of this article. IRC section 6901(c)(1) authorizes the IRS to collect against transferees beyond the normal limitations period.
Publication Name: Practical Tax Strategies
Subject: Law
ISSN: 0040-0165
Year: 1999
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