Robert Hunt IRS Memo - Dangerous

Unclassified – Approved for Theater Wide Distribution
Date: November 21, 2007
To: Expats
From: Steven Palazzo, Expat CPA
Re: The Robert Hunt IRS Memo

Everyone I know working overseas in a combat zone probably has seen this memo. Let me tell you once and for all this memo does not apply to civilian contractors working in combat zones. This memo was released for a very small group of Coalition Provisional Authority Personnel and the only thing it did was allow them additional time to file their tax returns. It did not provide a full Combat Zone tax exclusion. There is no such thing. It did not waive their 330 day overseas requirement. This still must be met every twelve months. The only exclusion of income must be earned by meeting the presence test or in some instances the bona fide residence test.

Can you imagine the number of people who have erroneously relied on this and are now facing audits, liens and tax seizures. Do you also know that you can’t even use this memo as a defense because it does not tell you your income is excluded, it does not tell you are tax free, it does not tell you can come and go to the US and not meet the 330 overseas requirement.

This memo has been grossly misinterpreted. It does not provide you any tax relief whatsoever and I’ve confirmed this on several occasions with the Office of Chief Counsel (International) Internal Revenue Service.

This link http://www.palazzocpa.com/bogusmemo.php will provide you with the only authority you need to know for working overseas as a civilian in a combat zone and it also provide you with the link to the Robert Hunt IRS memo.

Please help others by emailing to your Human Resources department so they can distribute Theater wide and share with your coworkers. I’m also available to assist and answer any questions that may arise.

Regards,
Steven Palazzo, CPA
Palazzo & Co, CPA
PO Box 4634
Biloxi, MS 39535
228-396-8800 - Office
866-272-9224 - Toll Free
305-768-0483 - Fax
WWW.PALAZZOCPA.COM
spalazzo@palazzocpa.com

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