Estate Planning Valuation Discounts Under Section 2704: An Update

Introduction For about a generation, families have taken minority discounts when valuing interest in closely-held businesses for estate, gift and generation-skipping transfer tax purposes. This popular estate planning technique is often used by families to minimize transfer taxes while maintaining continuity of their ownership in closely-held family-owned businesses. This technique was ...

U.S. Citizens Retiring Abroad: “Tax Trigger” Situations and Related Disclosure Forms

The following is a bolded checklist of important situations that may “trigger” a tax review by a skilled United States tax professional. Many of these situations also require a simultaneous review by a foreign tax professional. It is generally best practice for these tax professionals to work together to minimize ...

New Relief for Meeting the 60-Day Limit for IRA and Retirement Plan Rollovers

IRA and retirement plan rollovers are common occurrences, but they can be confusing. There a variety of rules and procedures which must be followed and mistakes may be costly. In addition to the potential for the rollover payment to become subject to income tax, it may also be subject to the 10% penalty tax ...

AccountingToday Article Provides Tax Primer: “Global Commerce 101”

Owners of small to mid-size U.S. businesses are finding the world is a smaller place, which can be very good for business. However, the opportunities of the international marketplace come with additional responsibilities, especially in the area of global taxation. AccountingToday’s July 2016 magazine contains a good “primer” on international business ...

Use State Voluntary Taxpayer Disclosure When Complying with Expanded Nexus

I. Introduction

Over the past 25 years new types of expanded non-physical nexus have come to be recognized. These types of expanded nexus are:
  • Economic Nexus: Income Taxes
  • Click-Through or Agency Nexus: Sales Taxes
  • Affiliate and Attributional Nexus: Sales Taxes and Income Taxes
Failing to comply with those expanded nexus standards can be ...

The Power of Voluntary Taxpayer Disclosure

Today the Boston Globe reported that PTC, Inc. (“PTC”) voluntarily disclosed that its Chinese subsidiaries allegedly provided about $1.5 million in bribes to foreign officials over a period of five years (from 2006 through 2011) in violation of the United States Foreign Corrupt Practices Act. PTC is a publicly held ...

State Voluntary Taxpayer Disclosure Programs: An Overview

State Voluntary Disclosure Programs: An Overview[1]

By Attorney Morris N. Robinson, CPA, LLM[2]

What is Voluntary Disclosure? Most state departments of revenue[3] allow certain categories of noncompliant taxpayers to come forward voluntarily and pay taxes accrued during a limited lookback period.[4] Taxpayers ...

UPDATE: IRS Withdraws Proposed Regulations on Substantiation of Donations in Response to Taxpayer Comments

Back in September of 2015, the Treasury and IRS issued proposed regulations related to section 170(f)(8)(D) providing an alternate framework for substantiating charitable donations. The proposal would require a donee organization to obtain the donor’s taxpayer identification number, along with other identifying information such as name and address. This information ...

Will Travel Insurance Cover This? Your Passport Can Be Denied or Revoked for Seriously Delinquent Taxes

If you wrote “travel more” on your 2016 New Year’s resolutions list, you may want to make sure you’re in good standing with the IRS before you make plans to wander too far from home. In early December 2015, legislation was enacted to add section 7345 titled “Revocation or Denial ...

The United States Taxation of Bitcoins and Transactions Denominated in Bitcoins

Introduction On March 25, 2014 the Internal Revenue Service published Notice 2014-21 which described the United States taxation of Bitcoins[1] and the United States taxation of transactions denominated in Bitcoins. This Notice generally treats Bitcoins as “property.”[2] The IRS guidance tracked a Financial Crimes Enforcement Network "Guidance" ...