The Moment You Have All Been Waiting For: Payroll Tax Guidance for 2013

The IRS released Notice 1036 to assist employer’s with determining the payroll tax consequences of the fiscal cliff. 2013 Withholding Tables. Notice 1036 includes the 2013 Percentage Method Tables for Income Tax Withholding. Employers should implement the 2013 withholding tables as soon as possible, but not later than February 15, 2013. Employers can use the … Continue reading The Moment You Have All Been Waiting For: Payroll Tax Guidance for 2013

Revised Withholding Calculation Rules for Nonresident Alien Employees

The IRS recently announced in Notice 2011-12 that Notice 2009-91 will not apply to wages paid after December 31, 2010.  Previously, Notice 2009-91 revised the withholding calculation rules for nonresident alien employees performing services within the United States.  Notice 2009-91 revised the rules to take into account changes made in the withholding tables to reflect … Continue reading Revised Withholding Calculation Rules for Nonresident Alien Employees

Curiouser and Curiouser: The Sourcing of Guarantee Fees Rises Again

By Jonathan Prokup It seems that one of our favorite topics is back in the news: the sourcing of guarantee fees.  As reported in today’s Tax Notes, Robert Driscoll, withholding technical advisor for LMSB, was recently quoted as saying that guarantee fees might not be considered U.S.-source income if the guarantor is a qualified resident … Continue reading Curiouser and Curiouser: The Sourcing of Guarantee Fees Rises Again

What Would Happen If A Taxpayer Asks The IRS For The Same “Deal” That Timothy Geithner Got?

By George W. Connelly As my readers know, I focus my practice on representing people who have “misunderstandings” with the Internal Revenue Service.  I can’t count the number of clients who have made a comment along the lines of “get me Geithner’s deal” since it came to light that he had some significant and frankly embarrassing … Continue reading What Would Happen If A Taxpayer Asks The IRS For The Same “Deal” That Timothy Geithner Got?

Lee Sheppard Takes on Container Corp.

By Jonathan Prokup In her column last Monday, Lee Sheppard criticized Judge Holmes of the Tax Court for, as she put it, “strain[ing] to find a reason to hold for the taxpayer” in the recent case of Container Corp. v. Comm’r, 134. T.C. No. 5.  (For our prior discussion of this case, see here.  For … Continue reading Lee Sheppard Takes on Container Corp.