TG 3-3 Exempt Purpose, Charitable IRC 501(c)(3). TG 3-3, a 59-page gem, provides guidance on, basically, the meaning of exempt purposes described in section 501(c)(3) of Title 26 of the Internal Revenue Code (“Code”). In this regard, section 501 of
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Texas Mixed Beverage Taxes
By TL Fahring
Chapter 183 defines a “permittee” is defined as someone who holds one of the following permits under the Texas Alcoholic Beverage Code:…
Does a Treaty Govern FBAR Reporting Obligations: A Federal Court Answers “Yes”
Much of the current litigation between taxpayers and the United States has centered on the definition of willfulness or whether…
Fraudulent Transfers | Burdens of Proof
With respect to actual fraudulent transfers, Plaintiffs must provide evidence that the Debtor made each transfer with actual…
Taxation in the U.S. Virgin Islands
By TL Fahring
The Mirror Code. As a territory, the U.S. Congress is empowered to “make all needful Rules and Regulations respecting” the USVI.[2] As far as…
Buying Real Estate in Coastal Mexico: Tax Implications in the U.S. & Mexico
A Mexican Trust created by a U.S. investor to acquire real estate within the restricted zone serving purpose is to hold title to the property.…
Monetized Installment Sales Make the IRS’s “Dirty Dozen” List for the Second Straight Year
The IRS has for the second time in as many years included monetized installment sales on its annual ……
Tax Court in Brief | Belton v. Comm’r | “Seriously Delinquent Tax Debt” and IRS Requirement to Comply with Lien Procedure
By Freeman Law
Petitioners, Willard Belton and Martha-Alexander Belton (Petitioners or Beltons) seeks review pursuant to section 7345(e) ……
Fraudulent Transfers | Insolvency
So this is the fourth in my expected five-part series on fraudulent transfers. In previous blogs, I laid out the basic statutory framework regarding fraudulent transfers, as well as a described generally the difference between actual and constructively fraudulent transfers…
Tax Court in Brief | Smith v. Comm’r | Exclusion of Value of Lodging Provided by Employer
By Freeman Law
This is a deficiency case and a continuation of the Tax Court’s opinion in Smith v. Commissioner, which is blogged right here on ……