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Archive for Ronald Marini

Criminal Defense Lawyer’s 5th Amendment Privilege Trumps An IRS Summon

Ronald Marini

According to Law360, A Minnesota federal judge has denied the IRS’ request to enforce a summons against a local criminal defense lawyer the agency accused of hiding tax-related information, agreeing with his Fifth Amendment objection citing the right against self-incrimination.

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Is This The End of Discounting Transfer Taxes With LLCs And FLPs?

Ron Marini

In the late 1980s, two Texas attorneys, John Porter and Stacy Eastland, introduced a new discounting technique relating to the formation of family limited partnerships, which resulted in discounts of 30% and more to the value of the artificially created family limited partnership (FLP). This technique was an anathema to the Internal Revenue Service; a review of many estate tax court cases litigated in the last 20 years involve the discounts taken on FLPs. The bulk of these discounts were related to intra-family transfers, many times saving millions of dollars in estate tax.

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Cayman Islands—FATCA Reporting of American Depositors Has Been Postponed Again!

Ron Marini

Previously, we posted “Cayman Islands FATCA Reporting Of American Depositors Is Today!” The Cayman Islands has postponed the deadline for banks to report accounts of U.S. and U.K. persons for the 2015 tax year to the Cayman Tax Information Authority from August 10 to September 2 for both U.S. Foreign Account Tax Compliance Act reporting and U.K. Crown Dependencies/Overseas Territories reporting.

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Required Record Doctrine Does Not Trump 5th Amendment Privilege in the Second Circuit

Ronald Marini

We previously posted Trouble for Offshore Bank Account Owners at Liechtensteinische Landesbank AG (LLB), which discussed tax problems for offshore bank account holders in Lichtenstein dates back to 2008 when information stolen from LGT Group was used by German authorities to prosecute tax fraud. The fallout extended to U.S. depositors at LGT who were investigated by the IRS. One of the U.S. depositors that got caught in this expanded IRS investigation was the defendant Steven Greenfield.

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Cayman Islands FATCA Reporting Of American Depositors Is Today!

Ronald Marini

Today, Wednesday, August 10, 2016 is the deadline for Cayman Islands financial institutions to complete their notification and reporting of American clients’ accounts to the Cayman Tax Information Authority, under the US Foreign Account Tax Compliance Act (FATCA).

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IRS Warns Of Summer Surge In Automated Phone Scam Call

Ron Marini

The IRS has seen an increase in “robo-calls” where scammers leave urgent callback requests through the phone telling taxpayers to call back to settle their tax bill. These fake calls generally claim to be the last warning before legal action is taken. Once the victim calls back, the scammers may threaten to arrest, deport or revoke the driver’s license of the victim if they don’t agree to pay.

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US Escapes The OECD’s Blacklist Of “Non-Cooperative Jurisdictions”

Ron Marini

The Organization for Economic Cooperation and Development has asked the G20 governments to approve its proposed three-step formula for deciding which international financial centers are to be blacklisted as non-cooperative.

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101 Countries Now Committed To OECD Common Reporing Standards

Ron Marini

According to an OECD announcement on May 12, 2016 global tax transparency forum, Panama, Vanuatu, Bahrain, Lebanon, and Nauru have now formally committed to share financial account information automatically with other countries using the Common Reporting Standard (CRS). This raises to 101 the number of jurisdictions committed to implement information sharing in accordance with the OECD’s Common Reporting Standard.

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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

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