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Archive for Ronald Marini

Tax Havens Coming Clean and Becoming Transparent

Ron Marini

The Cayman Islands has gazetted the Confidential Information Disclosure Law 2016, thereby repealing the Confidential Relationships (Preservation) Law with immediate effect as of June 2016. The old law was seldom used but was often cited as evidence of Cayman’s secrecy. The new law returns liability for breach of confidence to the common law and rules of equity, as in the United Kingdom.

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State Income Taxes Play A Role In Free Agency

Ron Marini

According to Law360, the free agent signing period in the NBA this month saw players inking huge contracts, but while team names and deal numbers dominated the headlines, experts say the tax implications of those moves often play an unheralded but critical role in determining where the leagues’ stars call home.

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It Takes Expats 13 Days To Complete All Required US Tax Forms!

Ron Marini

tax advisory law & chartered accounting firm created a chart which estimated the amount of time U.S. expats spend filing their statutory tax declarations.
An analysis of the chart provided by Moodys Gartner, considering only the most common types of forms that need to be filed annually for most expats, indicate that it takes roughly 106 hours or 13 working days to for expats to complete the necessary forms for their annual U.S. tax filings.  Read more

Mid-Year National Tax Advocate’s Report Is Wary Of IRS’ “Future State”

Ron Marini

In her 2016 mid-year report to Congress, National Taxpayer Advocate (NTA) Nina Olson has again expressed concern about IRS’s “Future State” plans. The report envisions how the agency will operate in five years and beyond. In addition, the NTA presents a review of the 2016 filing season and identified the priority issues that the Taxpayer Advocate Service (TAS) will address during the upcoming fiscal year.

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Argentina and Barcelona Soccer Player Leo Messi Handed Jail Term In Spain For Tax Fraud

Ron Marini

On July 6, 2016, a Spanish court sentenced the Argentine soccer superstar Lionel Messi to 21 months in jail after he was found guilty of tax fraud for using offshore companies to avoid paying Spanish taxes on advertising contracts.

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Federal Agents And Prosecutors Gearing Up To Utilize “Panama Papers” In Their Prosecutions

Ron Marini

Federal agents and prosecutors are “chomping at the bit” to exploit the Panama Papers and launch prosecutions, a senior federal law enforcement official told NBC News, but want to be sure that the way the huge data dump about offshore money was obtained doesn’t jeopardize their cases.

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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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