Author Archives: Morris Robinson

Business Income Tax Rates Slashed: Planning Pointers and Traps

The Tax Cuts and Jobs Act slashes business income tax rates on certain types of business income.
  • The 20% Qualified Business Income Tax Deduction slashes the top individual income tax rate on certain business income from 37% to 6%.
  • The 37.5% Foreign-Derived Intangible Income (FDII) Deduction slashes the C corporation income
...

“Tax-Favored” Foreign Income: Planning Pointers and Traps, An Overview of the FDII and GILTI Deductions

The Tax Cuts and Jobs Act (TCJA) reduces the corporate income tax rates of C corporations to 21 percent. The TCJA further reduces the C corporation income arising from tax-favored foreign income by means of two deductions:
  • The Foreign-Derived Intangible Income (FDII) deduction equals 37.5 percent of FDII and results
...

IRS Bitcoin Enforcement: Four Suggestions for Cryptocurrency Investors

In January 2018, an individual investor visited my office and asked me to prepare income tax returns based on his cryptocurrency trading gains.  This individual used U.S. dollars to buy Bitcoins.  He proceeded to trade in and out of other cryptocurrencies (“altcoins”) on a major trading exchange.  When he first ...

The Qualified Business Income Deduction: Interim Guidance

On March 7, 2018, David J. Kautter announced that official guidance on the qualified business income deduction will not be available until the late summer or early fall. Mr. Kautter was responding to a letter dated February 21, 2018 from the American Institute of CPA’s (“AICPA”) requesting immediate guidance to resolve the many ambiguities in the qualified business income deduction (Section 199A).

IRS Is Closing Offshore Voluntary Disclosure Program; Deadline of September 28, 2018

The IRS announced it will be closing its Offshore Voluntary Disclosure Program (OVDP) as of September 28, 2018. The news follows a significant decrease in taxpayer participation in the program, coupled with advances in third-party reporting of offshore account information and increased awareness of reporting obligations. All submissions made by the deadline must ...

Wire Transfer Audits and FATCA: What Every Taxpayer Needs to Know

Wire Transfer Audits and FATCA

What Every Taxpayer Needs to Know

by Attorney Morris N. Robinson, CPA, LLM

February 19, 2018

1. FATCA

FATCA: The Foreign Account Tax Compliance Act[1] was signed into law by President Obama on March 18, 2010. There ...

Smith v. Comm’r: Before You Take that Business-Related Tax Loss, Ask “Does My Business Have a Bona Fide Purpose?”

Last fall, the U.S. Tax Court decided the case of Smith v. Comm’r.[1] It’s not a pivotal case, but it stands as a good reminder of the adage “you don’t get something for nothing.” At the heart of the case was a complicated tax planning strategy using an ...

IRS Notice 2018-01: Passport Denial/Revocation for “Seriously Delinquent Tax Debts” to Begin

In 2015, the Fixing America's Surface Transportation (FAST) Act contained a provision in which the IRS would interact with the State Department to deny or revoke the passports of taxpayers with "seriously delinquent tax debts." However, details needed to be worked out between the two agencies before the effort could begin. On January ...

Donor-Advised Funds: IRS Proposes Rule Changes

Donor-Advised Funds: IRS Proposes Rule Changes

A Review of IRS Notice 2017-73[1]

By Attorney Morris N. Robinson, CPA, LLM

January 5, 2018

Background IRS Notice 2017-73 (the “Notice”) provides advance notice of U.S. Treasury and IRS’ proposed rule changes for Donor-Advised Funds (“DAF’s”).[2] ...

Estate and Gift Tax Audits: TIGTA Report Exposes Need for Improvement

While proposals for the eventual elimination of the estate tax are being hashed out in Congress, the IRS effort of auditing estate tax returns continues - business as usual. A recent report by the Treasury Inspector General for Tax Administration (TIGTA) highlighted ...