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Archive for Ronald Marini

Offshore Banks Liability For Client’s Tax Evasion

ron marini may 26

According to Law360 Offshore Tax Havens and Nominee Entities pose a significant regulatory and compliance risks to international financial institutions.

Regulatory authorities around the world, including the U.S. Department of Justice, intensified their investigations into offshore tax havens after the April 3, 2016, publication of names associated with the Panamanian law firm Mossack Fonseca, widely known as the “Panama Papers,” and the firestorm of public outcry.

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Revised Offer in Compromise Procedures—Not Current on ALL Tax Filings No OIC

ron marini may

The IRS is taking a close look at the Offer in Compromise program recently.

On March 30, 2016 we posted IRS Revises Offer in Compromise Booklet and Application where we discussed that the 2016 revision to Offer in Compromise Booklet Form 656-B will is available for download. The booklet contains necessary forms and instructions for submitting an Offer in Compromise. Use of earlier versions may result in a delay in the processing of Offer applications.

Now the IRS has released its new policy that effective immediately, the IRS will return newly filed Offer in Compromise (OIC) applications in cases where the taxpayer has not filed all required tax returns (e-News for Tax Professionals 2016-19- May13, 2016). Any fees included with the OIC will also be returned.

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U.S. Department of Justice Gets Its 1st FATCA Conviction!

Ron Marini May 17 2016

DoJ announced on May 9, 2016, that Gregg R. Mulholland, a dual U.S. and Canadian citizen of San Juan Capistrano, California and Vancouver, Canada, Age: 46 and secret owner of Legacy Global Markets S.A. (Legacy), an offshore broker-dealer and investment management company based in Panama City, Panama, and Belize City, Belize, pleaded guilty to money laundering conspiracy for fraudulently manipulating the stocks of more than 40 U.S. publicly-traded companies and then laundering more than $250 million in profits through at least five offshore law firms.

When sentenced, Mulholland faces up to 20 years in prison.

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Mossack Fonseca Affected Taxpayers with Potential Exposure Should Consult with Counsel To Consider Their Legal Options Now!

Ronald Marini

On May 12, 2016 we posted The Saga of the “Panama Papers” Has Only Just Begun! where we discussed that on May 6, 2016 the ICIJ announced that the unknown source behind a leak of 11.5 million financial and legal documents regarding shell companies from the Panamanian law firm Mossack Fonseca has offered to provide the same documents to governments that he gave to a team of reporters.  Read more

The Saga of the “Panama Papers” Has Only Just Begun!

Ronald Marini

Well the world has been abuzz as a result of the leaked information from Panamanian Law Firm Mossack Fonseca in April of this year. It appears, at least to me, that hopefully the original informant “John Doe” has cut some type of deal for immunity, with the various interested countries around the world. Read more

2015 Posts the Deepest Decline in Offshore Investments in 10 years!

Ronald Marini

Companies invested $221 billion into shell companies last year and investment flows to offshore tax havens such as the Cayman Islands and the British Virgin Islands fell somewhat, to $72 billion, according to the United Nations Conference on Trade and Development reported on May 3, 2016.

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Possible CbC Optional Reporting for 2016 Under Consideration by US Treasury

Ronald Marini

Speaking at a April 28,2016 transfer pricing symposium held by the University of San Diego School of Law, Robert Stack, US Treasury Deputy Assistant Secretary (International Tax Affairs) addressed the “gap-year” issue arising from the implementation of CbC reporting in some jurisdictions for tax years beginning on or after 1 Read more

Self-Employment Tax Rules Apply To Disregrarded Entities

Ronald Marini

Self-Employment Tax Rules Apply To Partnerships, IRS Says


Members of a partnership that owns a so-called disregarded entity, or a business that has a single owner and is not a corporation, are not exempt from self-employment tax rules, the Internal Revenue Service Read more

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.”
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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