Collecting Tax Liabilities from Third Parties

Research output: Contribution to journalArticlepeer-review


Creditors call it fraud. Debtors call it asset protection. I call it the “asset shuffle.” Whatever you call it, it is an age-old dance done by debtors trying to keep their assets from creditors they don’t like. Debtors either transfer assets to favored parties or else try to disguise their true interests in assets. <br><br>Over time, the IRS has developed three counter-moves to the asset shuffle. This article explains how the IRS uses those counter-moves to collect from third parties, parties who may become your clients and who are at risk for such collection actions. The key to helping such clients --- including knowing even what questions to ask them --- is to understand how the IRS takes property from third parties to satisfy the tax liability of a taxpayer. <br><br>The names for the IRS counter-moves are “Transferee,” “Nominee,” and “Alter Ego” liability. The three names describe the three types of special relationships that might allow the IRS to collect the taxpayer’s
Original languageEnglish
Pages (from-to)1549-1558
JournalTax Notes
StatePublished - Sep 12 2016


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