Morris Robinson

Morris Robinson

M. Robinson & Company, P.C.

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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...more

10/4/2016 - Carry Forward Commercial Bankruptcy Corporate Taxes Income Taxes IRS Net Operating Losses Tax Deductions Tax Returns

Estate Planning Valuation Discounts Under Section 2704: An Update

For about a generation, families have taken minority discounts when valuing interest in closely-held businesses for estate, gift and generation-skipping transfer tax purposes. This popular estate planning technique is often...more

9/23/2016 - Business Valuations Closely Held Businesses Estate Planning Estate Tax Family Businesses Generation-Skipping Transfer Gift Tax Internal Revenue Code (IRC) Public Comment Transfer of Assets U.S. Treasury

U.S. Citizens Retiring Abroad: “Tax Trigger” Situations and Related Disclosure Forms

The following is a bolded checklist of important situations that may “trigger” a tax review by a skilled United States tax professional. Many of these situations also require a simultaneous review by a foreign tax...more

9/13/2016 - Disclosure Requirements Domicile FBAR Foreign Corporations Foreign Earned Income Foreign Tax Credits Foreign Trusts Income Taxes Life Insurance Mutual Funds Non-Resident Aliens Retirement Retirement Plan Self-Employment Tax Tax Liability

Use State Voluntary Disclosure When Complying with Expanded Nexus

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 -...more

3/15/2016 - Affiliates Click-Through Nexus Corporate Taxes Economic Presence Nexus Voluntary Disclosure

The Power of Voluntary Disclosure

Yesterday the Boston Globe reported that PTC, Inc. (“PTC”) voluntarily disclosed that its Chinese subsidiaries allegedly provided about $1.5 million in bribes to foreign officials over a period of five years (from 2006...more

2/18/2016 - Offers in Compromise Tax Amnesty Tax Liability Voluntary Disclosure

The United States Taxation of Bitcoins and Transactions Denominated in Bitcoins

On March 25, 2014 the Internal Revenue Service published Notice 2014-21 which described the United States taxation of Bitcoins and the United States taxation of transactions denominated in Bitcoins. This Notice generally...more

1/7/2016 - Barter Bitcoin Fair Market Value FinCEN IRS Popular Virtual Currency

Jerry Lucente Speaks

Jerry Lucente is a Small Business/Self Employed Territory Manager with the North Atlantic Region of IRS, which includes the six New England states, New York and New Jersey. He is responsible for four groups at IRS that...more

12/17/2015 - Audits High Net-Worth IRS Offshore Banks Partnerships Voluntary Disclosure

The IRS’ Proposed Regulations to Provide a Substitute to the “Contemporaneous Written Acknowledgment” Requirement: A Data Security...

If you are a donor who makes a charitable gift of $250 or more, you need to obtain a “contemporaneous written acknowledgment” (CWA) letter from the recipient charitable organization to substantiate your donation and take the...more

12/16/2015 - Charitable Donations Confidential Information Data Security Identity Theft IRS Privacy Concerns Tax Deductions

State Voluntary Disclosure Programs: An Overview

What is Voluntary Disclosure? Most state departments of revenue allow certain categories of noncompliant taxpayers to come forward voluntarily and pay taxes accrued during a limited lookback period. Taxpayers accepted...more

12/8/2015 - Department of Revenue State Taxes Tax Penalties Voluntary Disclosure Voluntary Disclosure Agreement

Contributions of Art: Elements of a “Boring” Charitable Contribution Deduction

This article highlights some of the more critical income tax issues that taxpayers and their advisors must address when claiming the charitable contribution deduction for the gift of art to art museums. This article does not...more

10/23/2015 - Appraisal Art Charitable Deductions Charitable Donations Gifts Income Taxes Itemized Deductions Museums Private Foundations Public Charities Tax Returns

The Bank of America Case: May Massachusetts Tax the Trust Fund Income of Non-Resident Families with Unborn and/or Unascertained...

Background - Before addressing the Bank of America case, it is necessary to understand the Massachusetts taxation of trustees and their beneficiaries, which is described in 830 CMR 62.20.1: Income Tax on Estates and...more

10/23/2015 - Appeals Bank of America Beneficiaries Dormant Commerce Clause Estate Tax Jurisdiction Non-Residents Tax Appeals Tax Court Trust Funds Trustees Trusts

Massachusetts Non-Filer Amnesty Details Revealed

In early March of this year Governor Charlie Baker proposed a tax amnesty for taxpayers who have not filed tax returns with the Massachusetts Department of Revenue. According to reports published over the Internet, MDOR will...more

6/8/2015 - Department of Revenue Tax Amnesty Voluntary Disclosure

Preventing Double Taxation of Interstate Income: Supreme Court’s “Wynne” Decision is a Win for Taxpayers

In a five-to-four decision, the United States Supreme Court held that the dormant commerce clause protects in-state residents from the double taxation of their interstate income. This is a complicated decision and the margin...more

6/4/2015 - Comptroller of the Treasury v Wynne Dormant Commerce Clause Double Taxation Income Taxes Interstate Commerce SCOTUS State Taxes

Data Security Breach at IRS Disrupts Taxpayers and Tax Professionals

The Internal Revenue Service (IRS) announced on Tuesday, May 26, 2015 that criminals had fraudulently obtained the tax returns and account information of more than 100,000 taxpayers. The criminals used this information to...more

5/28/2015 - CPAs Fraud Identity Theft IRS Popular Power of Attorney Security Breach Tax Returns

U.S. Taxpayers Living Overseas: The June 15th Automatic 2-Month Extended Deadline and Other Filings Extensions

While most U.S. taxpayers must file their taxes by April 15th, U.S. taxpayers living abroad have additional options to extend the deadline of their filing due date. These extensions provide convenience as well as important...more

5/22/2015 - Filing Deadlines Foreign Taxpayers Tax Returns Time Extensions

Expect MDOR Audit Delays After the July 4, 2015 Holiday

Governor Charlie Baker’s recent plan to trim the number of Massachusetts employees was recently signed into law. According to published reports, more than half of all employees at the Massachusetts Department of Revenue are...more

5/13/2015 - Audits Charlie Baker Department of Revenue Early Retirement New Legislation Public Employees

Practice Tips for New Tax Associates

We are tax law specialists with a focus on international and Massachusetts taxation. I have drafted this memorandum to help new tax associates understand what is expected of them. This memorandum covers tips on drafting...more

3/17/2015 - Contract Drafting Engagement Letters Legal Ethics

Dealing with Erroneous FATCA Inquiries

A foreign bank asks our client to provide information that the bank is not required to provide IRS under FATCA. There are two possibilities. Our client can provide the information or our client can choose not to provide the...more

3/2/2015 - FATCA Foreign Banks IRS OVDP

Choosing the “Right” Income Tax Return Preparer

The IRS audits about one taxpayer in ten who reports more than $1 million in income. Many of these taxpayers are at the height of their careers and cannot endure even a whiff of scandal. They need peace of mind so they can...more

2/19/2015 - Audits IRS Tax Preparers

New IRS Appeals Procedures Complicate Tax Dispute Resolution

This article describes and evaluates the new IRS Appeals Office policy for handling IRS audit appeals. This new policy is known as the Appeals Judicial Approach and Culture (“AJAC”) Project. The stated goals of the AJAC...more

10/23/2014 - Audits Dispute Resolution IRS Tax Appeals

IRS Announces Sweeping Changes To Its Offshore Voluntary Disclosure Programs: New Rules Effective July 1, 2014

On Wednesday, June 18, 2014 the Internal Revenue Service announced sweeping changes to its Offshore Voluntary Disclosure Programs, effective Tuesday, July 1, 2014. Some taxpayers are treated much more leniently under expanded...more

6/25/2014 - Compliance FATCA FBAR IRS OVDP Reporting Requirements

Defending Federal and State Tax Audits For High-Income Taxpayers

In 2013 the IRS audited slightly over one taxpayer in nine[1] with an income of $1 million or more.[2] This audit rate represents a sharp 69 percent increase from the 6.42 percent audit rate that similar high-income...more

4/17/2014 - Audits Federal Taxes Income Taxes IRS State Taxes

The New Massachusetts Income Sourcing Rules For Corporate Services: Massachusetts DOR Issues Working Draft of Implementing...

On July 24, 2013 the Massachusetts General Court enacted an $800 million transportation bill. This bill, inter alia, revised the Massachusetts corporate sourcing rules for the sale of services. The bill became effective as of...more

4/3/2014 - Income Taxes Revenue State Taxes Trucking Industry

Commissioner Amy Pitter Announces Impressive Mediation Goal: One-Third of All Disputes Involving $250,000 or More To Be Mediated

Boston, February 10, 2014 - In her remarks before the Annual State Tax Conference of the Massachusetts Society of CPAs at the Sheraton Framingham on Thursday, January 23, 2014, Commissioner Pitter announced an impressive goal...more

2/12/2014 - Department of Revenue Mediation State Taxes

Massachusetts Imposes New Sales and Use Taxes on Computer System Design and Software Modification Services

The Massachusetts Department of Revenue (“DOR”) will formally announce deferral of compliance with the Massachusetts “tech tax” early next week, according to reliable and informed sources. The deferral announcement is...more

9/13/2013 - Computer-System Design/Software Services Sales & Use Tax Software

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