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Archive for Ronald Marini

The IRS Has Posted An Update To The Instructions For Form 8938 For 2014

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This update reflects changes to the Form 8938 reporting requirements made in the final regulations under section 6038D of the Internal Revenue Code (“final section 6038D regulations”).  TD 9706, 79 FR 73817, 2014-53 IRB 890 (December 12, 2014).  It also contains additional information not included in the published 2014 Instructions for Form 8938 (Rev. December 2014) (“published 2014 instructions”).

Dual Resident Taxpayers
The final section 6038D regulations have changed the reporting rules for dual resident taxpayers, effective for taxable years beginning after December 19, 2011.  For this reason, the published 2014 instructions and the instructions for Form 8938 for prior years are modified as provided in this update. Read more

Ex-TigerDirect Executives Charged In $9M Kickback Plot, Get Years In Prison For Fraud

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Gilbert Fiorentino, 54, and Carl Fiorentino, 57, both of Coral Gables, Florida, were sentenced in Federal Court in the Southern District of Florida, in connection with their participation in an illegal scheme to obtain more than $11 million dollars in kickbacks and other benefits, and to conceal this illicit income from the IRS, while employed as senior executives at Systemax, Inc. (“Systemax”) and its subsidiary, TigerDirect, Inc. (“TigerDirect”).

Carl Fiorentino was sentenced to 80 months’ imprisonment. Gilbert Fiorentino was sentenced to 60 months’ imprisonment. A hearing to determine the remaining amount of restitution owed to Systemax by the defendants, who are brothers, has been scheduled for April 3, 2015. Read more

IRS Actively Seeking US Tax Dodgers Abroad!


According to Bloomberg (subscription required) The Department of Justice Tax Division is ramping up an intense crackdown on offshore tax evasion, and people hiding assets overseas should come forward as soon as possible, an agency official said March 6, 2015. Caroline D. Ciraolo , principal deputy assistant attorney general for policy and planning at the division said:

“Time is of the essence,”
“Come in now or face the consequences.”

Speaking at the Federal Bar Association Tax Law Conference, Ciraolo said the government’s reach has extended far beyond Switzerland to jurisdictions including: Read more

IRS Opens Gateway for Exchange of FATCA Data on U.S. Owned Foreign Accounts

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The gateway is now open for the system countries will use to transmit information on U.S.-owned overseas accounts under the Foreign Account Tax Compliance Act, the IRS announces. All enrollees can use the system to securely send account reports under FATCA, which requires foreign financial institutions to transmit information to the IRS on accounts held by U.S. taxpayers.

The Internal Revenue Service’s Large Business & International division has opened a gateway that financial institutions and the tax authorities abroad can use to send information on financial accounts held by U.S. taxpayers in accordance with the Foreign Account Tax Compliance Act. Read more

IRS Says 3 out of 5 Still Need to File Their 2014 Tax Returns

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Issue Number:    IR-2015-38

WASHINGTON — With almost 59 million tax returns filed so far, the Internal Revenue Service estimates that three out of five taxpayers have yet to file their tax returns, according to statistics released today.

For taxpayers still working on their taxes, the Internal Revenue Service added three revised publications to just this week. These publications will help businesses and individuals understand how to figure depreciation as well as pension options.

Publication 946, How to Depreciate Property explains how you can recover the cost of business or income-producing property through deductions for depreciation. The Read more

OECD Announces New Country-by-Country Reporting Standard Starting in 2016!


On 02/06/15 the OECD and G20 countries have agreed three key elements that will enable implementation of the BEPS Project:

• a mandate to launch negotiations on a multilateral instrument to streamline implementation of tax treaty-related BEPS measures;

• an implementation package

     • for country-by-country reporting in 2016 and

     • government-to-government exchange mechanism to start in 2017;

• criteria to assess whether preferential treatment regimes for intellectual property Read more

FATCA Update! – 112 FATCA Agreements To Date!

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Since our last FATCA update which we posted on Monday, December 1, 2014, FATCA Update! – 101 FATCA Agreement To Date! the following 11 countries have signed FATCA agreements with the US  bringing the total to 112 jurisdictions with FATCA agreement including:

1. The U.S. and Seychelles sign agreement to implement FATCA. Seychelles is about to sign a Model 1B inter-governmental agreement (IGA) with the US to implement the US Foreign Account Tax Compliance Act. The Seychelles Revenue Commission will collect the information from domestic financial institutions and exchange it with the US Internal Revenue Service annually. Read more

Estate Tax Inequities (Changing Domiciliary)

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Last year, Joan Rivers died with an estate of roughly $100 million. In her last will and testament she described herself as a resident of New York State but a domiciliary of the State of California. What’s the difference?

Prior to 2000, there was no difference and all estates that paid federal taxes had to pay state death taxes based on a pickup chart listed on the tax return. It was a graduated tax predicated on the size of the estate; every estate, however, irrespective of domicile, paid the same amount on a percentage basis to the state of domicile. Circa 2000, the IRS disconnected the state death tax payments from the federal tax. The result was that some states chose not to have any state death tax while other states levied a substantial tax of their own. Read more

DOJ Continues To Prosecute Offshore Bankers Who Have Aided Taxpayers To Avoid US Taxes!

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Bloomberg News reports that federal prosecutors in Manhattan filed an expanded indictment Wednesday against former Wegelin & Co. bankers Roger Keller, Urs Frei and Michael Berlinka.

On Wednesday, August 28, 2013 we posted U.S. Turns Up The Pressure On Swiss Banks! where we discussed that thousands of Swiss bank workers have seen their data handed over to justice authorities in the United States and are now living with a considerable amount of uncertainty.

Now three Swiss bankers accused in 2012 of helping Americans hide more than $1.2 billion from the U.S. Internal Revenue Service face new charges of obstructing the Read more

UBS Whistleblower Bradley Birkenfeld Subpoenaed By French Authorities


A former UBS AG banker whose disclosures led the U.S. Department of Justice to investigate the Swiss bank for helping its American clients evade taxes has asked a Florida federal judge for permission to travel to France to aid in that country’s scrutiny of the bank, after receiving a subpoena from a French magistrate judge.

Bradley Birkenfeld filed a motion on Friday saying he had received a subpoena to appear before French Magistrate Judge Guillaume Daieff in Paris later this month to help the judge and French law enforcement with their investigation into the bank’s activities.

“The subpoena commands Mr. Birkenfeld to assist the investigation by appearing before him to provide testimony in his chambers,” the motion said. “Through French counsel, Read more

IRS Begins Limited Test of Providing Appointments at 10 Walk-In Locations

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The Internal Revenue Service announced today a limited test in 10 of its larger Tax Assistance Centers around the country to determine if an appointment-based service approach can help reduce taxpayer wait times during a time of severe budget cuts.

While the IRS believes this approach will benefit taxpayers by helping them avoid long waits in line that they otherwise might have experienced, the IRS is testing this process during the tax filing season to ensure this is a more efficient approach for taxpayers.

“During a challenging filing season with a very limited budget, we need to find ways to increase our efficiency and still provide the best service possible to taxpayers,” said IRS Commissioner John Koskinen. “My hope is that this test increases the level of customer Read more