Category Archives: Tax Planning

“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 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 ...

A Quick To-Do List for “Tax Season”

The deadline for individuals to file and pay their 2017 taxes will be Tuesday, April 17, 2018, which is six weeks from now.  As we continue to work through “tax season,” I suggest that taxpayers add a withholding review to their to-do list for “tax season.”

IRS Announces Withholding Tax Changes for 2018

IRS Announces Withholding Tax Changes for 2018: Employers and Employees Should Review Their W-4 Forms During “Tax Season” By Yale Yechiel N. Robinson The Massachusetts Tax Alert™ The Internal Revenue Service (IRS) announced on February 28, 2018 that it has updated its online withholding calculator and the W-4 form to comply with the new tax rates under the Tax Cuts and Jobs Act of 2017.  Most employers have already adopted the new tax withholding tables for their employees’ wages based on the revised IRS Notice 1036.

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 ...