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Archive for Ronald Marini

Big Businesses Lobby For 3.5% Offshore Repatriation Tax

Ron Marini

According to various news reports, U.S. multinationals are “pushing” the U.S. government to further reduce the tax rate on offshore profits. Major U.S. multinationals are pushing the Trump administration to deepen the tax break it has already tentatively proposed on $2.6 trillion in corporate profits being held offshore by more than 500 U.S. companies.

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Tax Reform Dead? No Plan B Without Border Tax?

Ron Marini

Previously, we discussed the that the most realistic baseline scenario regarding tax legislation is that there is a repeal of the ACA and associated taxes. While at this time, it is unclear what a replacement bill may look like.

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The OVDP Program May End After 2017

Ron Marini

U.S. taxpayers who have foreign bank and/or financial accounts should be watching the clock. The window to voluntarily report foreign accounts in order to mitigate IRS penalties may be ending after 2017.

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Are You Hiding Assets In The BVI?

Ron Marini

The British Virgin Islands’ Government has signed new legislation regarding Beneficial Ownership & Technical Protocol with the UK which will come into force in June 2017, which is hoped to improve the exchange of beneficial ownership information between the UK & BVI law enforcement for taxation rulings.

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Predicting Which Tax Proposals Become Law

Ron Marini

According to a recent Wells Fargo Monthly Economic Outlook, they have incorporated a set of fiscal policy assumptions based on what we think is the most likely outcome based on policy proposals from President Trump and senior congressional leaders.

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Negligence Penalty Where Partner Omits Partnership Item

Ron Marini

The Tax Court has held that, where a partner omits a partnership item from his individual tax return, and the partnership itself was subject to a TEFRA audit, the Court has jurisdiction to determine that partner’s resulting negligence penalty.

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Summon Rules Applies To Taxpayer’s Marijuana Business

Ron Marini

Colorado- A district court has made several rulings regarding Code Sec. 280E, the Code section that disallows deductions in carrying on a trade or business that consists of trafficking in controlled substances.

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Tax Proposal Including Switch To A Territorial Tax System

Ron Marini, trump, tax proposal

According to a plan released by the White House on April 26, 2017, creating a 15% tax rate for corporations, cutting the top individual tax rate from 39.6% to 35%, reducing the number of rates from seven to three, and repealing a 3.8% tax on net investment income are the top priorities in the Trump administration’s tax reform agenda.

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Proposed 15% Corp. Tax Rate & Repeal of 3.8% Obama Tax

Ron Marini

A 15% tax rate for corporations, cutting the top individual tax rate from 39.6% to 35%, reducing the number of rates from seven to three and the repeal of a 3.8% tax on net investment income are the top priorities in the Trump administration’s tax reform agenda, according to a plan released by the White House today April 26, 2017.

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Corporate Executive Must Face Criminal Charges

Ron Marini

A software and hospitality executive accused of not withholding federal taxes must face criminal charges after the U.S. Supreme Court refused Monday to consider his challenge of a Sixth Circuit decision holding that those charges are not precluded by a civil suit court order forcing him to work without pay.

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1st U.S. Prosecution For False Expatriation Statement

Ron Marini

The IRS has been hunting for offshore income and accounts continues unabated well beyond UBS as evidenced by a former client of Credit Suisse Group AG who pleaded guilty to hiding $200 million from U.S. tax authorities.

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Financial Advisors Are Turning Over Your Names To The IRS

Ron Marini

The Government has added another Financial Advisor since October of 2016, Michael A. Behr, (effective 1/25/17) to their list of Offshore Banks and Foreign Financial Advisors which are turning over the names of their US Account Holders, who are now subject to a 50% (rather than 27.5%) penalty in the IRS’s Offshore Voluntary Disclosure Program (OVDP). This penalty is based on the highest account balance measured over up to eight years.

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