Category Archives: Entity Taxation

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

by Attorney Patricia Weisgerber, LL.M. 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 ...

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

by  Attorney Patricia Weisgerber, LL.M. 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 ...

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 ...

Building Wealth through Real Estate: Financial and Tax Policies of the United States Government That Can Lead To Significant Wealth through Real Estate Ownership

Financial and tax policies of the United States government can help Americans achieve significant wealth through real estate ownership. These policies tend to favor taxpayers who, like the Trump family, are willing to commit to "the long game”, where the full benefits of real estate ownership accrue over decades and ...

Tax Complications of a $1 Billion Dollar Net Operating Loss

Recently, The New York Times shared information that presidential candidate, Donald Trump, declared a loss of $916 million on his 1995 income tax returns. In response, there has been much speculation that Donald Trump may have violated the tax laws of the United States. This may be why he is under audit. ...

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 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" ...

Massachusetts Small Businesses Accepting Credit Cards May Face IRS Scrutiny

On August 10, 2013, the Wall Street Journal reported that IRS is issuing 20,000 letters to businesses that accept credit cards and asking them “to explain why the portion of [their] gross receipts from non-card payments appears unusually low.”  According to the Journal, the letters form ...

E-Filing of Business Certification Now Mandatory in Massachusetts

On October 4, 2012, the Massachusetts Department of Revenue published Department Directive 12-5. The purposes of that directive are (1) to require electronic filing of the Annual Certification of Entity Tax Status for entities in existence on January 1, 2013, and (2) to implement federal classification conformity in formulating the ...