Category Archives: Tax Planning

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

By Patricia Weisgerber, Esq., LL.M. 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 ...

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

by Patricia Weisgerber, Esq., LL.M. 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 ...

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

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

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 ...

An Overview of the Unified Republican Framework on Tax Reform

On September 27, 2017, President Trump and the Republicans unveiled the elements of their tax reform framework. Here’s a quick overview of some of the proposed changes: Individual Taxes Standard Deduction: Under the proposed framework, that standard deductions will approximately be doubled to:
  • $24,000 for married taxpayers filing jointly, and
  • $12,000 for single
...

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 ...