IRS’ application of petitioner’s remittance after the tax liabilities has been assessed constituted a payment of that tax liability.
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IRS’ application of petitioner’s remittance after the tax liabilities has been assessed constituted a payment of that tax liability.

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On December 28th, 2021 the US Tax Court reviewed and decided whether “the taxpayer has paid more than was owed, where such a determination is necessary for a correct and complete determination of whether the proposed collection action should proceed”. (per T.C. Memo. 2021-142 UNITED STATES TAX COURT Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent…

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Tax Implications When Foreigners Investing In Real Estate in the US

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Tax Implications When Foreigners Investing In Real Estate in the US The tax would be reported to the US because the property is located in the US. Under the treaty, it states ARTICLE 6 Income from Real Property1. Income derived by a resident of a Contracting State from real property (including income from agriculture or…