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23 States Join the Multistate Tax Commission Amnesty Ending on October 17, 2017: “Fulfillment by Amazon” Companies Targeted

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...more

Residency Tax Planning for Noncitizens Under IRS Publication 519

Noncitizens who intend to become residents of the United States are often well-advised to receive foreign-source earned income and recognize foreign-source capital gains before establishing residency in the United States. In...more

Massachusetts Joins MTC Amnesty Program

Massachusetts Joins Multistate Tax Commission Amnesty Program - For Most States Amnesty Features Complete Tax Forgiveness - Urgent Action May Be Needed - Boston – On August 18, 2017 Massachusetts joined 22 other...more

IRS Announces Tax Audit Targets

Over the past several years, IRS has reduced the number of its tax auditors by about 25 percent – from just over 12,000 tax auditors in 2011 to about 9,000 tax auditors in 2015. This staffing reduction has forced IRS to focus...more

IRS Targets Globally-Mobile Individuals and Businesses: The Importance of Proactive Planning

IRS targets globally-mobile individuals and businesses through its Global High Wealth Industry Group and its Large Business and International Division. Targeted taxpayers find these audits distracting, taking time from...more

IRS Targets the Wealthy via Wealth Squad

IRS operates a Wealth Squad, which brings together teams of IRS specialists to coordinate the audit of wealthy taxpayers. IRS identifies wealthy “targets” with secret algorithms that are skewed against the wealthy. IRS also...more

4/6/2017  /  IRS , Tax Audits , Tax Liability

For High-Income and International Taxpayers: Defensive Tax Planning

The Importance of Defensive Tax Planning - IRS audit criteria target high-income taxpayers, especially those with reported foreign income or foreign financial assets. Targeted high income taxpayers include...more

The Importance of Defensive Tax Planning and Defensive Tax Return Preparation

Executive Summary: The Importance of Defensive Tax Planning - Tax reform is in the news again. But until we achieve significant tax reform it is essential that individuals, trusts and estates, and businesses with incomes...more

Net Operating Loss Carryforwards on President Trump’s 2005 Income Tax Return

James B. Stewart, writing for The New York Times (March 23, 2017), explored the complexities of President Donald Trump’s 2005 U.S. income tax return, which was revealed publicly last week. President Trump used $103 million...more

Personal Liability of Executors for Tax Liabilities of the Estate Under the Federal Priority Statute, 31 U.S.C. 3713

This is an appeal of summary judgment by the personal representative (the “PR”) of an estate. The lower court found the PR to be personally liable under the federal priority statute, Section 3713, for tax liabilities due from...more

Statute of Limitations and Collections Process Against Executrix and Agent for Estate Tax Deficiency

United States v. Holmes - 2016 WL 4363398 (SD Tex. Aug. 16, 2016) Summary - Summary judgment was sought by both the taxpayers and the Government for an estate tax liability. The taxpayers contended that the...more

Massachusetts Governor Charlie Baker May Propose Unconstitutional Sales Tax Collection Responsibility on Remote Sellers

BOSTON – January 27, 2017. In an attempt to balance his $40.5 billion budget, Governor Charlie Baker may propose that remote sellers be required to collect Massachusetts sales taxes on sales of tangible personal property made...more

Becoming As Rich As Donald Trump: Financial and Tax Policies of the United States Government That Can Lead To Significant Wealth...

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...more

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

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

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

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

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

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

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

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

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

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

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

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

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