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Archive for Ronald Marini

Apple, Inc. To Pay $38 Billion In Repatriation Taxes

Ronald Marini, Tax Advisor, Tax Blog, Miami, Florida, USA, TaxConnections

Apple, Inc. said it would make a one-time tax payment of $38 billion to repatriate overseas cash holdings and also ramp up its spending in the U.S., as it seeks to emphasize its contributions to the U.S. economy after years of taking criticism for outsourcing manufacturing to China. As Of Last September, Apple Had $252 Billion.

In Cash Or Cash Equivalents Abroad  Read more

Apple Could Get A $4B Timing Reduction In TCJA’S 15.5% Transition Tax?

Ronald Marini, Tax Advisor, Miami, FL, TaxConnections

According to taxproToday, Companies that stockpiled trillions of dollars offshore free of U.S. income tax may get one last break before paying up, provided their fiscal years don’t follow the calendar year.

A timing quirk in the tax overhaul that President Donald Trump signed last month may be good news for companies such as Apple Inc., Microsoft Corp. and Cisco Systems Inc., all of which began their fiscal years before Jan. 1. Firms including Alphabet Inc., Amgen Inc. and General Electric Co., with fiscal years that began on Jan. 1, appear to be shut out of the benefit. Read more

Canadian Court Allows Extradition Of Tax Shelter Promoter

Ronald Marini, Tax Connections

A Canadian court has granted the U.S. government’s request to extradite a tax attorney who is facing charges back home accusing him of helping former partners of Ernst & Young LLP develop and market fraudulent tax shelters, while dodging more than $8 million in taxes himself. A Canadian court has granted the U.S. government’s request to extradite a tax attorney who is facing charges back home accusing him of helping former partners of Ernst & Young LLP develop and market fraudulent tax shelters, while dodging more than $8 million in taxes himself. Read more

DOJ Seeks Tenfold Increase in Criminal Sentencing for Offshore Tax Matters

The US Department of Justice (DoJ) has announced a significant change in its criminal sentencing policy regarding offshore tax violations. The DOJ had previously Warn Potential Tax Cheats: Tax Crimes Result In Criminal Prosecution, Lengthy Prison Sentences, And Fines on April 6, 2017.

Mark Daly, DOJ Tax Division Senior Litigation Counsel announced a major new shift in how the Department of Justice plans to argue offshore tax prosecution defendants should be sentenced.

He gave a warning that the department now considers that Part 2S1.3 of the United States Sentencing Guidelines, referring to money laundering and monetary transaction reporting offences, applies to offshore tax cases, and not Part 2T (offences involving taxation), as was previously used.

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Senate Passes $1.4 Trillion Tax Cut Legislation

Ronald Marini, Tax Advisor

According to Law360, The U.S. Senate passed an expansive tax cut bill early Saturday that is projected to add more than $1 trillion to the deficit, after garnering enough support from faltering and fiscally conservative Republicans.According to Law360, The U.S. Senate passed an expansive tax cut bill early Saturday that is projected to add more than $1 trillion to the deficit, after garnering enough support from faltering and fiscally conservative Republicans. The Tax Cuts and Jobs Act, or H.R. 1, passed by a vote of 51-49, with Sen. Bob Corker, R-Tenn., being the only Republican to vote against the bill. No Democrats voted in favor of the bill.

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Transferee Liability for Unpaid Corporate Taxes of Minority Shareholders

Ronald Marini, Tax Advisor

The Eleventh Circuit affirmed the Tax Court’s determination that petitioner was liable as a transferee under 26 U.S.C. 6901 for his former employer’s unpaid taxes, in Kardash v. Commissioner of IRS, US Court of Appeals for the Eleventh Circuit, Docket: 16-14254.
The Tax Court had previously found two minority shareholders liable to return several million of dividends they received from a corporation when the corporation failed to pay federal income taxes at the direction of majority shareholders, which majority shareholders also drove the company into insolvency by siphoning off corporate funds.

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More Then 31,000 US Taxpayers Exposed in Paradise Papers

Ronald Marini, Tax Advisor

We had posted on October 30, 2017 ‘Another Offshore Law Firm Gets Hacked’ where we discussed that Appleby, an offshore law firm/corporate agent’s recent data breach is yet another example of how the IRS can discover your unreported foreign account and how the super-rich clients of offshore law firm Appleby are bracing themselves for the exposure of their financial secrets, after the firm admitted data had been stolen in a cyber attack last year.

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OECD Report Finds That Tax Haven Islands Are Now Sharing Information

Ronald Marini, Tax Advisor

The Cayman Islands, Bermuda and Mauritius, three of the world’s most famous tax havens, are among the countries deemed “compliant” or “largely compliant” with international standards for tax information exchange, according to a series of reports released Monday by the Organization for Economic Cooperation and Development.

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House Passes Tax Bill With Deep Cuts For Businesses & Territorial Tax for Multinationals

Ronald Marini, Tax Advisor

Last week, House Republicans succeeded in passing wide-reaching tax legislation, overcoming Democrats’ criticisms that it would significantly lower taxes for corporations and the wealthy while short-changing middle-income earners.

The Tax Cuts and Jobs Act, or H.R. 1, was approved by a vote of 227-205 just two weeks after it was introduced. The legislation would have a significant impact on a wide range of industries including technology, energy, pharmaceuticals and real estate, but lawmakers must first iron out differences between the House bill and a companion version under consideration in the Senate.
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Senator Bernie Sanders Call For Senate Investigation of the Offshore Paradise Papers Leak

Ronald Marini, Tax Advisor

Senator Bernie Sanders (I-VT) called for the U.S. Senate to investigate offshore tax evasion following the revelations of the Paradise Papers, adding to the growing voices in Congress who have called for government to take action to address the investigation’s findings.

In a letter to Senate Budget Committee chair Mike Enzi (R-WY), Sanders called on the budget committee to launch a bipartisan investigation to determine how much the use of offshore havens has contributed to the U.S. national debt.

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