What to propose (and what the Service will accept) for an offer in compromise
Article Abstract:
Generally, the grounds for an IRS offer to compromise are based on doubt regarding the government's ability to collect liabilities from a taxpayer. Taxpayers making offers to compromise first must submit a Form 656, Offer in Compromise, and a Form 433, Statement of Financial Condition and Other Information, to the IRS. In cases of a taxpayer's inability to pay, the amount offered must: exceed the total value of the equity in all of the taxpayers' assets; give consideration of the taxpayer's future earning capacity; and be in compliance with all filing and paying requirements. The IRS, which has the discretion to reject any offer, will make a thorough financial examination of a statement of assets and liabilities. The practitioner representing the taxpayer should submit offers above, but close to, the taxpayer's net realizable equity and should be aware of the offer behavior at the local IRS office.
Publication Name: Taxation for Accountants
Subject: Business
ISSN: 0040-0165
Year: 1990
User Contributions:
Comment about this article or add new information about this topic:
Loan programs enhance the appeal of qualified plans
Article Abstract:
Participant loan programs increase employees' interest in qualified plans and are an economical technique for encouraging employees to partake of the benefits of such plans. The design of participant loan programs must be done in accordance with the numerous technical rules and regulations of the Internal Revenue Code, Department of Labor regulations, and the Truth in Lending Act. The IRS qualifications for participant loan programs are: the plan must not discriminate in favor of employees that are highly compensated, plan assets generally cannot be used as collateral for loans, and loans must be made within strict limits as to amount and time of repayment. DOL regulations articulated under the Employee Retirement Income Security Act include: interest rates of loans must be reasonable; loans must be secured; and loans can only be made in strict accordance with the plan's provisions.
Publication Name: Taxation for Accountants
Subject: Business
ISSN: 0040-0165
Year: 1991
User Contributions:
Comment about this article or add new information about this topic:
- Abstracts: Low and Bonar stuck in the wrong packet. Crest offers an improved package. RPC Group
- Abstracts: Jump-diffusion processes and the term structure of interest rates. Some aspects of equilibrium for a cross-section of firms signalling profitability with dividends: a note
- Abstracts: The impact of hypothesis set size on the time efficiency and accuracy of analytical review judgments. The impact of analytical review results, internal control reliability, and experience on auditors' use of analytical review
- Abstracts: Using a proportional odds model to analyze the factors that influence accounting standard setting lobbying in Australia
- Abstracts: Who do they think they're kidding? Britain's trade deficit: a symptom, not a disease. House price falls: how far, how fast?