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Archive for Ronald Marini

Nevada And Wyoming Asked To Provide Information On Entities Linked To The “Panama Papers”

Ron Marini

Senate Finance Committee Ranking Member Ron Wyden (D-OR) has asked the Nevada Secretary of State to provide specific information on over 1,000 Nevada business entities that have been linked to the so-called Panama Papers scandal.

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Ex-Credit Suisse Banker/Fugitive Pleads Guilty in Tax Evasion Case

Ron Marini

According to the Department of Justice, a former Credit Suisse AG banker, who has been a fugitive since 2011, pleaded guilty on June 22, 2016 in a U.S. District Court in the Eastern District of Virginia. The charges were related to aiding and assisting U.S. taxpayers in evading income taxes, as stated Acting Assistant Attorney General Caroline D. Ciraolo of the Justice Department’s Tax Division.

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Brexit-Associated Tax Issues Including Losing U.K. Corporate Tax Breaks Worth Billions!

Ron Marini

On June 24, 2016, UK citizens have voted to exit the European Union (Brexit) and its single market. There can be no doubt that the result of the so-called Brexit referendum will leave a permanent mark on UK and on EU itself. The first short-term negative effects have already presented themselves with the pound dropping to historically low levels and the Prime Minister David Cameron announcing his resignation in upcoming months.

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UBS Singapore Forced To Turn Over Records of US Taxpayer

Ron Marini

On August 28, 2013, we discussed the US putting pressure on Swiss Banks, acknowledging 2009 as the time when Switzerland’s biggest bank UBS agrees to turn over more than 4,450 client names and pay a $780 million fine after admitting to criminal wrongdoing in selling tax-evasion services to wealthy Americans.

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Tax Court Rejects Proposed IRS $1.36 Billion Tax Assessment

Ron Marini

The Tax Court rejected the IRS proposed transfer pricing method of re-allocating income between a U.S. parent corporation and its foreign subsidiary. Also, it ruled against the Service’s attempt to collect $1.36 billion in tax deficiencies, finding that the assessment did not reflect the economic realities of manufacturing these medical devices in a case involving Medtronic’s intellectual property licenses necessary to produce and sell high-risk, heavily regulated implantable technology.

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US Taxpayers Are Receiving $10,000 Penalty Assessments

Ron Marini

We recently posted an article discussing an influx of calls from businesses who have recently received penalty notices regarding late filed or non-filed Form 5472. The Internal Revenue Service imposes an automatic penalty of $10,000 whenever an individual or company is late in filing an information return disclosing their interest in a foreign corporation, regardless of whether there is any associated under-reporting of income or tax deficiencies.

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New IRS Procedure To Allow Request For Return Of Property

Ron Marini

We previously posted on November 10, 2014, IRS Seizure of Assets Using Anti-Structuring Laws, in which we discussed that there were a series of reported cases in which the IRS has seized money from innocent Americans based on purported violations of so-called “anti-structuring” laws, which make it a crime to deposit less than $10,000 cash in the bank in order to evade bank reporting requirements. Read more

41 Countries Committed To Sharing Beneficial Ownership Information

Ron Marini

We previously posted on April 25, 2016 that over 20 countries joined the UK-led pilot for automatic data sharing. 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 signed up. Now Her Majesty’s (HM) Treasury has published a list of 41 countries which have committed to sharing beneficial ownership information.

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U.S. Citizens’ Capital Gains Taxable Under U.S.-Israel Treaty

Ron Marini

The United States Tax Court has concluded that a pro se taxpayer who was a U.S. citizen and permanent Israel resident was taxable on his capital gains. Although the taxpayer argued that such gain was excluded from U.S. tax under one provision of the U.S.-Israel income tax treaty, the court nonetheless ruled the income taxable under the treaty’s “saving clause.”

After moving to Israel in 2009, Elazar Cole, a U.S. citizen, became a permanent resident of Israel in 2010. As a result of moving to Israel, he qualified for a ten-year Israeli “tax holiday,” which exempted him from Israeli tax on non-Israeli-source capital gain income. Indeed, Article 15, paragraph 1, of the Convention between the Government of the United States of America and the Government of Israel with Respect to Taxes on Income, U.S.-Israel, Nov. 20, 1975 provides that “[a] resident of one of the Contracting States shall be exempt from tax by the other Contracting State on gains from the sale, exchange, or other disposition of capital assets.”

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Mossack Fonseca Closes 3 Branch Offices In European Tax Havens

Ronald Marini

On May 6, 2016, the International Consortium of Investigative Journalists (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.

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Cayman Islands Will Not Show Theirs Until the U.S. Shows Theirs First

Ron Marini

We previously reported on the UK list of 40 countries that agree to automatically exchange beneficial ownership information, an updated list of jurisdictions it says have committed to its recent initiative. The list includes the Cayman Islands, Bermuda and Jersey, but not Guernsey or the British Virgin Islands, though Afghanistan and Nigeria are on the list.

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UK Lists 40 Countries that Agree to Automatic Exchange of Beneficial Ownership Information

Ron Marini

The United Kingdom (UK) released a list of countries it says have committed to its initiative for the automatic exchange of beneficial ownership information. The list includes the Cayman Islands, Bermuda and Jersey, but not Guernsey or the British Virgin Islands, though Afghanistan and Nigeria are on the list.

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