23 States Join the Multistate Tax Commission Amnesty Ending on October 17, 2017: “Fulfillment by Amazon” Companies Targeted

  By Attorney Morris N. Robinson, CPA, LLM[1]

Executive Summary

This article provides practitioners with a practical overview of (1) the changing law of nexus; (2) the Multistate Tax Commission Amnesty Program ending on October 17, 2017; and (3) on-going state voluntary disclosure programs. This article is particularly valuable ...

For Vendors Making Internet Sales to Massachusetts Customers-A New Proposed Regulation Expands the Definition of Tax Nexus

by Yale Yechiel N. Robinson, Esq. A new regulation in Massachusetts, 830 CMR 64H.1.7, will expand the definition of tax nexus for out-of-state vendors making internet sales to Massachusetts customers.  The regulation will become effective on October 1, 2017. Online sellers are subject to the new regulation if they meet the ...

Residency Tax Planning for Noncitizens Under IRS Publication 519

By Attorney Morris N. Robinson, CPA, LLM

Executive Summary

Noncitizens who intend to become residents of the United States are often well-advised to receive foreign-source earned income and recognize foreign-source capital gains before establishing residency in the United States. In our experience resident aliens and new ...

The Importance of Timely Electing Your Foreign Earned Income Exclusion

by Attorney Patricia Weisgerber, LL.M. Life as an American living abroad can conjure idyllic notions of painting en plein air in Paris or negotiating a last minute deal in Brussels. Not so idyllic, however, is the reality of filing U.S. tax returns from overseas. One of U.S. taxpayers living abroad is ...

Massachusetts Joins MTC Amnesty Program

Massachusetts Joins Multistate Tax Commission Amnesty Program For Most States Amnesty Features Complete Tax Forgiveness Urgent Action May Be Needed By Attorney Morris N. Robinson, CPA, LLM August 18, 2017 Boston – On August 18, 2017 Massachusetts joined 22 other participating states and the District of Columbia in offering a special limited-time tax amnesty through ...

“Drop Shipment” Sales Tax Rule Is Held Constitutional

In D & H Distributors, Inc. v. Commissioner of Revenue (July 31, 2017), the Massachusetts Supreme Judicial Court (SJC) upheld the imposition of sales tax against a wholesaler that delivered goods directly to consumers in “drop shipment” transactions.

SCORE! for the Boston Bruins – Jacobs v. Commissioner

by Attorney Patricia Weisgerber, LLM Like Napolean recognizing that an army marches on its stomach, the owners of the Boston Bruins know a hockey team needs to be well-fed to ensure optimal performance on game day. So, when the Bruins go on the road to play away-games, management plans ahead. With ...

FBAR Penalties Now Adjusted for Inflation: Abatement/Mitigation Still Possible

If you haven’t filed your Report of Foreign Bank and Financial Accounts (FBARs) on a timely basis, you could be at risk of a higher civil penalty assessment. Inflation-adjusted FBAR penalties are now in effect. New FBAR Civil Penalties Framework The statutory civil penalties most people are familiar with, and as reflected ...

2017 OVDP Declines and Withdrawals Campaign: Certain U.S. Taxpayers at Risk of Audit

In 2016, the Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers may use to become compliant if they previously had failed to report offshore income on their ...

IRS Announces Tax Audit Targets

IRS Announces Tax Audit Targets

By Attorney Morris N. Robinson, CPA, LLM

June 14, 2017

Over the past several years, IRS has reduced the number of its tax auditors by about 25 percent – from just over 12,000 tax auditors in 2011 to about 9,000 tax auditors ...