TaxConnections


 

Archive for Ronald Marini

Tax Court Rules For Amazon Against The IRS

Ron Marini

In 2015, Amazon was bitterly locked in a $1.5 billion transfer pricing dispute with the Internal Revenue Service over an arrangement it inked with a European subsidiary, and the outcome of the case, which is sitting in U.S. Tax Court, is being closely watched by multinationals and tax lawyers alike.

Read more

Breaking News – Possibly No Tax Reform This Year!

Ron Marini

After the election last year, we discussed that Donald Trump has proposed tax reforms that would:

  • significantly reduce marginal tax rates for both individuals and businesses,
  • increase standard deduction amounts to nearly four times current levels,
  • limit or repeal some tax expenditures,
  • repeal the individual and corporate alternative minimum taxes and the estate and gift taxes, and
  • tax the profits of foreign subsidiaries of US companies in the year they are earned.

Read more

2017 Budget Is Trouble For the IRS

Ron Marini

We previously discussed that IRS employees could be in for a rocky ride if President-elect Donald Trump and Congress move forward with sweeping pledges to rein federal employee benefits and cripple unions.

Read more

California Businessman Sentenced For Hiding $23.5 MM Offshore!

Ron Marini

A Californian businessman was sentenced to 24 months in prison today for hiding more than $23.5 million in offshore bank accounts and evading more than $8.3 Million in Federal Taxes over seven years.

Read more

FinCEN—FBARs Are Automatically Extended Until October 15!

Ron Marini

According to new law, returns for tax years beginning after Dec. 31, 2015, the due date of FinCEN Report 114 will be Apr. 15, with a maximum extension of 6 months ending on Oct. 15.

Read more

The Estate Tax Challenge

Ron Marini

President Trump’s tax plans includes the repeal of the US Estate & Gift taxes. This may be a realistic possibility considering that this is in line with some of the proposals in the Republican House Ways & Means Committee Report of June 24, 2016 and especially when you consider that now the Republican’s Control both the Senate and the Congress.

Read more

U.S. Businesses Split On Border Tax

Ron Marini

U.S. corporations are going to war in Washington over a Republican “border adjustment” tax proposal meant to boost exports over imports, with lawmakers in Congress coming under pressure from some of the nation’s biggest employers. The political split that is opening, most pronounced in the narrowly divided Senate, could doom the proposal. If it dies, prospects for a thorough tax code reform, a top 2017 goal for Republicans, would be diminished.

Read more

IRS Investigators Raid Caterpillar Over Swiss Profits

Ron Marini

Caterpillar Inc., an American manufacturing icon, used a wholly owned Swiss affiliate to shift $8 billion in profits from the United States to Switzerland to take advantage of a special 4 to 6% corporate tax rate it negotiated with the Swiss government and defer or avoid paying $2.4 billion in U.S. taxes to date, a new report from Sen. Carl Levin, the chairman of the U.S. Senate Permanent Subcommittee on Investigations shows.

Read more

IRS Criminal Investigation Releases 2016 Annual Report

Ron Marini

IRS criminal investigations have decreased over the past few years in the wake of a steady staffing decline, with the 2016 fiscal year seeing fewer cases involving identity theft, money laundering and other financial crimes, according to an agency report released Feb. 27, 2017.

Read more

New Zealand New Disclosure Requirements For Foreign Trusts

Ron Marini

The Taxation (Business Tax, Exchange of Information, and Remedial Matters) Bill includes the necessary measures for New Zealand to implement the G20/OECD standard for the Automatic Exchange of Information in Tax Matters, which New Zealand financial institutions will have to comply with, and measures to further strengthen and update New Zealand’s international tax rules with new disclosure requirements for foreign trusts.

Read more

Next Month Your U.S. Passport Could Be Revoked For Debts!

Ron Marini

H.R. 22, Fixing America’s Surface Transportation Act (FAST Act), includes amendments to the tax code that would allow authorities to revoke or deny the passport of any U.S. taxpayer who has unpaid taxes in excess of $50,000 or who have not obtained or won’t provide a Social Security numbers which was signed by President Obama on December 4, 2015. It now gives the U.S. government the right to revoke or deny the passports of U.S. persons who owe more than $50,000 in federal taxes (including penalties and interest) effective on January 1, 2016.

Read more

FinCEN Extends Tracking Secret Buyers Of Luxury Real Estate

Ron Marini

In 2016, I discussed in an article the Financial Crimes Enforcement Network (FinCEN) issuing a Geographic Targeting Orders (GTO) that will temporarily require certain U.S. title insurance companies to identify the natural persons behind companies used to pay “all cash” for high-end residential real estate in the Borough of Manhattan in New York City, New York, and Miami-Dade County, Florida.

Read more

TaxConnections