Jason B. Freeman's Blog

When a partner enters into a sale or exchange of their partnership interest, there are often lurking tax surprises—such as unexpected phantom income triggers.  Sales of partnership interests are notoriously fraught with potential tax traps for the unwary.  It is, in fact, even possible to trigger...

Taxpayers with interests in foreign financial assets, financial accounts, and/or foreign trusts may have certain tax reporting obligations with the IRS.  For example, taxpayers with a financial interest in or signature authority over foreign financial accounts with an aggregate value of over $10,...

 The following post is from Freeman Law, PLLC and can be viewed here.   IRS detection of tax fraud is up nearly 400%, largely from its use of data analytics.  According to its recent report, the IRS Criminal Investigation Division identified nearly $10 billion in tax fraud in 2018—an increase fro...

For more on What you Need to Know About Federal Tax Liens and Levies, visit Freeman Law for our Insights and in-depth resources on the topic.   A. Introduction In order to protect the revenue, Congress has provided an administrative means of collection on IRS assessments by attaching a lien to th...

For the past year, the IRS has been issuing taxpayers Notices of Certification of Seriously Delinquent Federal Tax Debt.  These notices inform taxpayers of serious consequences related to outstanding tax debts that are classified as "seriously delinquent," which can include the denial of passport...

Just before the turn of the new year, Congress passed—and the president signed—the Tax Cuts and Jobs Act of 2017 (“TCJA”).  The TCJA represents the most extensive rewrite of the U.S. tax code in over 30 years.  The new act contains a number of important provisions that will impact business tax pl...

The IRS recently announced that it will officially close the Offshore Voluntary Disclosure Program (“OVDP”) in September of 2018.  Its announcement serves as a “last call” for taxpayers who have willfully failed to report foreign assets or income—a last opportunity to come forward under the terms...

What are the tax implications of a cryptocurrency Hard Fork?  Does the holder of a cryptocurrency that undergoes a Hard Fork realize taxable income? If so, how does one determine the amount of the income and when, exactly, it is received?  These are not easy questions to answer.What is a Hard For...

Sensitive audits present the tax practitioner with unique challenges.  They require the exercise of judgment and discretion, as well as an understanding of administrative procedure and even a command of constitutional and evidentiary rules.  At times, they may also require that the practitioner c...

We are in the midst of a revolution-a digital transformation driven by what many believe could be the most powerful decentralizing force since the rise of the Internet: Blockchain. It is difficult to overstate the potential impact of this technology and its applications. Much as the double-entry ...