Quick answer: If you are asking do I have to respond to IRS Letter 6174, the short answer is no. Letters 6174 and 6174-A are “soft” educational letters that do not require a response. Letter 6173 is different: it generally requires a written response within about 30 days, and ignoring it can trigger an examination.…
Continue reading ›The short answer to the FBAR vs. Form 8938 question is that they are two separate filings with different rules, and many taxpayers have to file both. The FBAR (FinCEN Form 114) goes to the Treasury Department and reports foreign financial accounts once they top $10,000 in total. Form 8938 is a FATCA form filed…
Continue reading ›The core FBAR filing requirement is straightforward: a U.S. person who has a financial interest in, or signature authority over, foreign financial accounts must file an FBAR if the combined value of those accounts tops $10,000 at any point during the calendar year. The FBAR is FinCEN Form 114, and it is filed electronically, separately…
Continue reading ›To fight a California residency audit, you have to do more than say you moved. The Franchise Tax Board (FTB) starts from the assumption that you never really left, and it will test that assumption against your bank records, travel history, and daily location data. Winning means responding carefully, documenting where your life actually centers,…
Continue reading ›The California billionaire tax, Proposition 40 on the November 3, 2026 ballot, proposes a one-time 5% tax on the net worth of state residents worth $1 billion or more. As written, it would reach only a few hundred people. Its real significance for the broader high-net-worth community is what it signals: California is sharpening its…
Continue reading ›Claiming the Qualified Small Business Stock exclusion on your tax return is not the finish line. It is the moment the position becomes reviewable. A QSBS audit is the IRS’s examination of whether a Section 1202 exclusion was actually earned, and because these claims routinely shelter seven- and eight-figure gains, they draw serious attention. When…
Continue reading ›Qualified Small Business Stock (QSBS) is one of the most powerful tax benefits available to founders, early employees, and investors. Under Section 1202 of the Internal Revenue Code, a taxpayer who holds qualifying stock in a small C corporation can exclude a large portion, and in many cases all, of the capital gain when the…
Continue reading ›California’s proposed billionaire tax has put the California residency audit back in the national spotlight, and made it the single most important issue for wealthy individuals who have recently left the state or are thinking about it. As Proposition 40, the 2026 Billionaire Tax Act, heads toward a statewide vote, the California Franchise Tax Board…
Continue reading ›Tax professionals and taxpayers alike have noticed a shift: IRS frivolous return notices (Letter 3176C) are landing on returns that claimed ordinary tax credits, not the tax-protester filings the program was built to catch. If you claimed a credit you believed you were entitled to and received a notice calling your position frivolous, the explanation…
Continue reading ›Receiving a frivolous return notice when you filed an ordinary, good-faith tax return is jarring. The IRS uses the word “frivolous” to describe positions it considers baseless — the stuff of tax-protester theories — yet a growing number of taxpayers are getting these letters (IRS Letter 3176C) for returns that were nothing of the sort.…
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