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Archive for Ronald Marini

What Are The Chances You Will Face An IRS Audit?

Ronald Marini

After much worry and angst you successfully met the filing deadline for your tax return. Now you are obsessing about a new worry: Will that return be audited by the IRS?

Almost everyone dreads the thought of an IRS audit but thanks to continuing Congressional cuts in the IRS budget, fewer and fewer Americans will face an audit of their return. For the 83% of Read more

The Newly Issued Form 1042-S – Foreign Person’s U.S. Source Income Subject to Withholding

Ronald Marini

IRS has issued the 2016 version of Form 1042-S, Foreign Persons’ U.S. Source Income Subject to Withholding, and the instructions for that form. The form requests even more information then the 2015 version of this form!

What’s New In 2016:

Substitute forms. A substitute form furnished to a recipient must conform in format and size to the official IRS form and contain the exact same information as the copy filed with the IRS. However, the size of the form may be adjusted if the Read more

Mossack Fonseca Law Firm Leak & Attorney-Client Privilege

Ronald Marini

We previously posted DoJ Launches Criminal Investigation of Hundreds of US Taxpayers Named in Panama Papers Leak! where we discussed that the offshore planning world was set on fire with the news that 11 million documents were leaked from the Panamanian law firm Mossack Fonseca.

They allegedly show how Mossack Fonseca has helped clients launder money, dodge sanctions and evade tax and now The Guardian reports that U.S. Attorney Preet Bharara has “led several crusades against criminal wrongdoing in the financial sector, is already investigating several of the more than 200 US citizens named in the papers.”
Read more

Over 20 Countries Join UK-led Pilot for Automatic Data Sharing

Ronald Marini

Chancellor of the Exchequer, George Osborne hailed the international expansion of a UK-led deal to automatically share information on the ultimate owners of companies as over 20 jurisdictions, including British crown dependencies, overseas territories and EU member states sign up.

Gibraltar, Isle of Man and Montserrat are amongst those joining the pilot initiated by the UK and launched with Germany, France, Italy and Read more

The IRS Issues New Version of Form W-8 BEN-E

Ronald Marini

 

On December 17, 2014 we posted How to Complete Form W-8 BEN E & and W-8IMY? where we discussed how to fill out the various Form W–8’s, which now has increased to 8 pages in some cases.

This post provided foreign entities a set of step-by-step instructions to complete the new Forms W-8BEN-E and W-8IMY, as well as a general overview of the obligations imposed on foreign financial institutions under the new chapter 4 FATCA regime including: Read more

DoJ Launches Criminal Investigation of Hundreds of US Taxpayers

Ronald Marini

On April 4, 2016 we posted Huge Leak From the Panamanian Law Firm Mossack Fonseca! where we discussed that the offshore planning world was set on fire with the news that 11 million documents were leaked from the Panamanian law firm Mossack Fonseca.  They allegedly show how Mossack Fonseca has helped clients launder money, dodge sanctions and evade tax.

This post also speculated that U.S. persons will probably show up, Read more

SCOTUS Declined Review of CA Decision Denying Foreign Tax Credit For Taxes Settled > 10Yrs After Return Was Filed

Ronald Marini

The Supreme Court has declined to review a decision of the Court of Appeals for the Federal Circuit that denied, as time-barred, a corporation’s refund claim for disputed foreign tax credits (FTCs). The Federal Circuit concluded that the 10-year statute of limitation period in Code Sec. 6511(d)(3)(A) for filing such claims began with date for filing the return for the year in which the foreign taxes originated, and not for the year in which the amount of the Read more

Have An Un-Reported Account Associated With Mossack Fonseca? Like Your Freedom?

Ronald Marini

On April 4, 2016 we posted Huge Leak From the Panamanian Law Firm Mossack Fonseca! where we discussed that the offshore planning world was set on fire with the news that 11 million documents were leaked from the Panamanian law firm Mossack Fonseca.  They allegedly show how Mossack Fonseca has helped clients launder money, dodge sanctions and evade tax. The company says it has operated beyond reproach for 40 years and has never been charged with criminal wrong-doing. Read more

US Pressured For Beneficial Ownership Rules

Ron Marini

We previously posted, Get Ready For The US Proposed Plan to Require Banks to Identify Owners of Shell Companies! where we discussed that the United States government is close to issuing a rule that will for the first time require banks and other financial institutions to find out the identities of people hidden behind shell companies.

The rule is meant to close a major loophole in the American Read more

Mandatory Public CbC Reporting Proposed by the OECD!

marini2

On April 12, 2016 the European Commission presented a proposal that would require all large Multinational Enterprises with operations in the European Union to Publicly Disclose certain tax-related information for all their entities in the EU and in designated tax havens on a country-by-country (CbC) basis.

The European Commission has indicated that it will establish a common EU list of tax haven jurisdictions as soon as possible. Read more

Panamanian Police Raid The Law Offices of Mossack Fonseca Just 10 Days After Leek!

Ron Marini

On April 4, 2016 we posted Huge Leak From the Panamanian Law Firm Mossack Fonseca! where we discussed that, the offshore planning world was set on fire with the news that 11 million documents were leaked from the Panamanian law firm Mossack Fonseca.

They showed how Mossack Fonseca has helped clients launder money, dodge sanctions and evade tax. The company says it has Read more

Tax Time Guide: Easy Electronic Payment & Payment Agreement Options!

Ron Marini

As it is tax time we thought that it would be a good time to remind taxpayers that it’s easier than ever to pay their taxes electronically, and for those who can’t pay on time, quick and easy solutions are available.

Taxpayers who owe taxes can now choose among several quick and easy electronic payment options, including the following: Read more

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