California Sales Tax and Cannabis This installment of the Tax and Vice Blog will focus on a recent California Sales Tax and Cannabis Tax case heard by the California Office of Tax Appeals (OTA). The OTA sided with the CDTFA and ruled against the Taxpayer in Appeal of Sacramental Native American Church (SNAC). While there
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What to Look for When Hiring a Tax Attorney
Hiring a Tax Attorney Are you in need of a tax attorney? If so, it is essential to understand what to look for when hiring a tax attorney. Typically, individuals seek the services of an attorney when they find themselves in an unfortunate legal situation, they are unable to navigate independently. When searching for a
IRS Form 8300 – What Is It and Why Is It Important?
IRS Form 8300 If you engage in a business or trade that receives large cash payments, understanding IRS Form 8300 – what it is and why is it important – is crucial. The IRS mandates “each person engaged in a trade or business who, in the course of that trade or business, receives more than
How Does a Bypass Trust Work?
Bypass Trust A Bypass Trust allows you to provide for your surviving spouse and leave assets to your children, without the burden of estate taxes. Some BackgroundAs of 2023, the federal estate tax exemption is $12,920,000. This means estates valued below that number are exempt from the federal estate tax. The value of an estate
Rethinking IRS Penalty Assessments: A Deep Dive into the Farhy v. Commissioner Ruling
Farhy v. Commissioner In a recent landmark ruling, Farhy v. Commissioner, the Tax Court has significantly changed penalty assessments under I.R.C. Section 6038(b) of the Internal Revenue Code. This ruling, rendered on April 3, 2023, carries significant implications for a broad range of taxpayers, potentially offering a basis to challenge or request refunds for penalties
What You Need to Know About FinCEN Form 105 – Importing Currency into the United States
What You Need to Know About FinCEN Form 105 As a city with a direct border to Mexico, San Diego is a popular destination for our Mexican neighbors who need to know about the FinCen Form 105 in order to bring currency into the United States for business or personal use. Those planning to import
Leveraging the Benefits of Form 8833 for International Tax Treatment
The International Tax Law Team at RJS LAW receives numerous inquiries regarding a crucial yet often misunderstood element of United States tax law — IRS Form 8833, or the Treaty-Based Return Position Disclosure. For taxpayers engaged in global transactions, Form 8833 is significant as cross border transactions are often regulated by international tax treaties. What
What is Step-Up Basis and How is it Beneficial for Trusts and Estates?
What is Step-Up Basis and How is it Beneficial for Trusts and Estates? Step-up basis allows for the tax basis to be stepped up to fair market value upon the transfer of an asset at death. What is basis? The IRS defines basis as “the amount of your capital investment in property for tax purposes.”
Understanding IRS Notices: Notice of Intent to Seize or Levy Your Property, CP504 Notice and CP504B Notice
The IRS CP504 Notice and CP504B Notice We continue our series on IRS notices by discussing the Notice of Intent to Seize (Levy) Your Property or IRS CP504 or CP504B Notice. While the verbiage of this notice can be somewhat confusing and cause some undue alarm, this blog post will discuss what the notice means
What happens if I did not file an FBAR? Can I do a Streamlined Procedure?
Introduction: Streamlined Procedure As an attorney specializing in international tax law, it is crucial to understand the consequences and available options for individuals who have failed to file their Foreign Bank and Financial Accounts (FBAR) reports. Failure to comply with FBAR reporting requirements may result in severe penalties. Fortunately, the Internal Revenue Service (IRS) offers