Author Archives: Morris Robinson

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 ...

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 ...

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 ...

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 ...

IRS Targets Globally-Mobile Individuals and Businesses: The Importance of Proactive Planning

IRS Targets Globally-Mobile Individuals and Businesses:

The Importance of Proactive Planning

By Attorney Morris N. Robinson, CPA, LLM

April 21, 2017

IRS targets globally-mobile individuals and businesses through its Global High Wealth Industry Group and its Large Business and International Division. Targeted taxpayers find these audits ...

IRS Targets the Wealthy via Wealth Squad

IRS Targets the Wealthy via Wealth Squad

By Attorney Morris N. Robinson, CPA, LL.M.

April 6, 2017

IRS operates a Wealth Squad, which brings together teams of IRS specialists to coordinate the audit of wealthy taxpayers. IRS identifies wealthy “targets” with secret algorithms that are skewed against ...

For High-Income and International Taxpayers: Defensive Tax Planning

For High-Income and International Taxpayers: Defensive Tax Planning By Attorney Morris N. Robinson, CPA, LLM[1] March 31, 2017 The Importance of Defensive Tax Planning IRS audit criteria target high-income taxpayers, especially those with reported foreign income or foreign financial assets. Targeted high income taxpayers include:
  • Individuals
  • Trusts and Estates
  • Corporations
  • Partnerships and LLCs
What ...

Net Operating Loss Carryforwards on President Trump’s 2005 Income Tax Return

James B. Stewart, writing for The New York Times (March 23, 2017), explored the complexities of President Donald Trump’s 2005 U.S. income tax return, which was revealed publicly last week.  President Trump used $103 million of net operating loss (NOL) carryforwards in 2005 to reduce his regular income tax. ...

Massachusetts May Target Remote Sellers for Sales Tax

In an attempt to balance his $40.5 billion budget, Massachusetts Gov. Charlie Baker (R) may propose that remote sellers be required to collect Massachusetts sales taxes on sales of tangible personal property made over the internet to Massachusetts residents. Attorney Morris N. Robinson sent a Letter to the Editor of State Tax Notes, suggesting that Governor Baker's proposal may be both impractical and unconstitutional.

Personal Liability of Executors for Tax Liabilities of the Estate Under the Federal Priority Statute, 31 U.S.C. 3713

United States v. McNicol 829 F.3d 77, (1st Cir. July 15, 2016) aff’g 2014 WL 4384486, 114 A.F.T.R. 2,d 2014-5919 (D. Mass., 2014) Summary This is an appeal of summary judgment by the personal representative (the “PR”) of an estate. The lower court found the PR to be personally liable under the federal ...