TaxConnections


 

Archive for Ronald Marini

Time to Compare Candidate’s Tax Plans Again!

Ron Marini

On July 19, 2016, we previously posted Time to Compare Candidate’s Tax Plans! where we discussed both the Clinton Tax Plan and the Trump Tax Plan. Now with the first debate, we thought it would be a good time to revisit their tax positions.

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Did You Know That President Obama Could Obtain Donald Trump’s Tax Returns?

Ron Marini

In this presidential election, the Republican candidate Donald Trump steadfastly refuses to release his tax returns. This has caused political blogs to have a lively discussion regarding whether President Obama could request Donald Trump’s tax returns from the Internal Revenue Service (IRS)?

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Your Offshore Confidential Information Is Being Delivered Daily To Tax Authorities – New Leak Of Bahamian Offshore Files!

Ron Marini

Once again the International Consortium of Investigative Journalists (ICIJ), the same group that released the now infamous “Panama Papers,” has now released a cache of leaked documents provides names of politicians and others linked to more than 175,000 Bahamian companies registered between 1990 and 2016!

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No More Face to Face Meetings at IRS Appeals Division?

Ron Marini

The IRS announced that effective Oct. 1, 2016, it will rarely conduct Appeals Conferences in person. More specifically, Internal Revenue Manual (IRM) 8.6.1.4, blandly entitled “Conference Practices,” provides that ALL conferences will be held by telephone except under certain specific enumerated circumstances.

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Singapore is Now Automatically Sharing Your Account Information!

Ron Marini

On July 25, 2016, we posted Tax Havens Coming Clean and Becoming Transparent where we discussed that the Inland Revenue Authority of Singapore has issued an e-Tax Guide on the territory’s general anti-avoidance rule in Section 33 of the Income Tax Act. The guide, issued on July 11, 2016, explains the three tests to determine whether the GAAR should apply.

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US – Israeli Dual Nationals Lose FATCA Challenge In Israel

Ron Marini

An Israeli Supreme Court panel has thrown out a challenge to a tax information-sharing agreement with the U.S. and removed a temporary block on FATCA’s implementation, rejecting arguments that the agreement violates the rights of Israelis.

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IRS Crack Down On Foreign Tax Credits For U.S. Multinationals

Ronald Marini

The U.S. Department of the Treasury revealed on September 15, 2016 that it is drafting rules to curb U.S. Multinationals from obtaining U.S. foreign tax credits as a result of foreign government’s audits resulting in foreign tax adjustments for U.S. Multinationals.

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U.S. Taxpayer Is Entitled To Penalty Abatement Based On Mental Incapacity

Ron Marini

In Chief Counsel Advice 201637012, released September 9, the IRS has determined that whether a taxpayer qualifies for abatement of failure to timely file and pay penalties turns on whether the delinquencies were caused by her mental incapacity.

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Have A FLP Or LLC With Valuation Discounts? Talk With Your Tax Advisor!

Ron Marini

We previously posted “Is This the End of Discounting Transfer Taxes with LLC’s and FLPs?” where we discussed that the Internal Revenue Service issued a proposed regulation which would beef up IRC Section 2704 of 1986 to preclude many of the presently available discounting techniques. In addition, this proposed regulation would expand the purview of section 2704 to include not only partnerships and corporations but LLCs, S corporations, and other family “business” transfer entities.

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Tax Preparers Request Injuction Against Assessment Of IRS Fees

R M 6.1

According to Law360, a certified class of more than a million tax preparers ranging from accountants to attorneys urged a D.C. federal judge Wednesday to block the Internal Revenue Service from charging a fee for issuing a preparer tax identification number, arguing the fee is unlawful.

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IRS CI Changes Phone & Fax Numbers for OVDP Preclearance!

Ron Marini

So here I am just another 59-year-old tax attorney who is sure that technology has it out for him, sitting in my office trying to get a few more cases moving forward while I wait for the Labor Day weekend, and I’m trying to fax (267) 941-1115 (the OVDP preclearance number) a preclearance for yet another client who wants to enter the OVDP program.

Naturally, I’m waiting for my E-Fax confirmation that this request for preclearance has gone through to the IRS and today I received not 1 but 2 messages that my E-Fax, that I rely on for communicating with the IRS, was not able to deliver either of my faxed requests.

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OVDP Is Not The Only Option For Taxpayers With Undisclosed Foreign Bank Accounts!

Ronald Marini

With the implementation of FATCA, the ongoing efforts of the IRS and the Department of Justice to ensure compliance by those with U.S. tax obligations have raised awareness of U.S. tax and information reporting obligations with respect to non-U.S. investments.

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