Author Archives: Morris Robinson

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 ...

International Tax Issues Are A Major Focus of Newest Launch of IRS Compliance Campaigns in 2017

Earlier this year, the IRS Large Business and International division (LB&I) rolled out 13 compliance campaigns[1] to target both individual taxpayers and corporations for examinations on certain tax compliance issues. On November 3, 2017, IRS announced the identification of an additional 11 compliance campaigns to be conducted by ...

Are Your Business Deductions at Risk of Being Disallowed by the IRS?

Small businesses run on tight margins. The last thing a business owner wants is an IRS notice announcing the disallowance any of their business expense deductions. This is particularly the case for sole proprietorships who report their business expenses on Schedule C of IRS Form 1040. For instance, deductions on Schedule ...

UPDATE: MTC Extends Deadline for Amnesty under the Online Marketplace Seller Voluntary Disclosure Initiative

Earlier today, the Multistate Tax Commission (MTC) released an update extending the October 17, 2017 deadline for businesses to file under its Online Marketplace Seller Voluntary Disclosure Initiative. The new deadline is now November 1, 2017. This initiative is specifically for businesses who are online marketplace sellers using a marketplace provider/facilitator ...