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§ 6662 Accuracy Related Penalty: Reasonable Cause And Good Faith

Can a taxpayer use the reasonable cause and good faith defense to avoid the accuracy-related penalty for an underpayment of tax pursuant to § 6662?

Debt vs. Equity

Is an interest in a corporation debt or equity for federal tax purposes?

CFC and PFIC Rules

Is a corporation a controlled foreign corporation or a passive investment foreign company for the purposes of the Internal Revenue Code?

Economic Substance

Does a transaction have economic substance for tax purposes?

Worker Classification

Is a worker an employee or an independent contractor for tax purposes?

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