Section 112020 of the “One Big Beautiful Bill Act” (OBBBA), House version, would expand the reach of the IRC § 4960 excise tax on compensation in excess of $1 million (equal to 21%, the...
Read this practice note discussing factoring transactions, the parties involved, and the reasons for factoring. This practice note specifically discusses the distinguishing features of advance and discount...
Land banking transactions are an alternative financing structure where the land banker (typically an investment group) purchases the land shortly before or soon after the homebuilder acquires it. The parties...
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In 2025, navigating the IRS's tax collection process is more critical than ever, as changing tax laws and economic shifts demand vigilance from both individuals and businesses. The IRS, armed with a formidable team of Revenue and Appeals Officers, is tasked with collecting taxes through various methods, from returns to levies. Once a tax liability is assessed—whether due to incomplete payments, substitute returns, or unchallenged Notices of Deficiency—IRS officers spring into action, aiming to collect the owed amounts while adhering to taxpayer protections under the Internal Revenue Code. Ignoring IRS notices can escalate to severe actions like liens, levies, or even jeopardy assessments, where assets can be seized without warning. By staying informed and proactive, taxpayers can effectively manage their obligations, avoid penalties, and maintain financial stability amidst the IRS's rigorous collection efforts.
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