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Archive for Ronald Marini

U.S. Taxpayers & Their Advisors Serving Jail Time

Previously we discussed that the IRS hunt for offshore income and accounts continues unabated well beyond UBS. In fact, it’s intensifying and for those who don’t come forward before they are found, being found can be awfully painful. See list of UBS criminal convictions, so far.

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Border Tariff, Border Adjustment Tax, Or U.S. VAT?

Ron Marini

Earlier this month, we posted an article, “Border Tariff or Border Adjustment Tax?,” where we discussed that there’s a lot of talk these days about borders and taxes in Washington. U.S. President Donald Trump wants to hit firms that outsource with a simple tariff on imports. Republicans in Congress have pitched a more complex idea, a border adjustment, built into a corporate-tax overhaul.

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A Former Credit Suisse Client Gets a 7 Month Jail Sentence!

Ron Marini

We previously posted on November 7, 2016 we posted “Swiss Bank Rats Out NYU Business Professor – Results in Fine of $100M & Up To 5 Yrs in Prison” where we discussed that a former client of Credit Suisse Group AG who pleaded guilty to hiding $200 million from U.S. tax authorities was sentenced to seven months in prison after a judge granted him leniency for cooperating with prosecutors, a Justice Department official said.

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BEPS Project May Have Set Backs – EU’s Apple Decision

Ron Marini

In September, 2016, we discussed that the European Commission’s probe into Apple, which resulted in an order for the tech giant to pay up to €13 billion ($14.5 billion) in back taxes to Ireland, was prompted by a U.S. Senate investigation, European Union Competition Commissioner Margrethe Vestager said on Friday.

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IRS Has 13 New Compliance Campaigns For LB&I Taxpayers

Ron Marini

We previously posted on October 9, 2015 LB&I Agents Lose Autonomy To Centralized Office That Will Be Using Data to Identify Compliance Risks For Audit! where we discussed that tax practitioners will face new questions from examination teams as the IRS selects compliance risks based on data, in the Large Business and International Division’s (LB&I) move from individual audits of multinationals to broader considerations involving risk assessment.

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Anti-Money Laundering Obligations – Latin America Customers

Ron Marini

There is an increasing number of tax regularization programs in Latin America—most recently in Argentina, Brazil, Colombia, and Peru—is of keen interest to the cross-border wealth management industry, as per Jones Day.

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Border Tariff Or Border Adjustment Tax?

Ron Marini

There’s a lot of talk these days about borders and taxes in Washington. U.S. President Donald Trump wants to hit firms that outsource with a simple tariff on imports. Republicans in Congress have pitched a more complex idea, a border adjustment, built into a corporate-tax overhaul. We sort through the winners and losers.

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New Filing Dates For 2016 U.S. Tax Returns

Ron Marini

On July 31, 2015, President Obama signed into law P.L. 114-41, the “Surface Transportation and Veterans Health Care Choice Improvement Act of 2015,” which includes a number of important tax provisions, including revised due dates for partnership, S corporations and C corporation returns and revised extended due dates for some returns.

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You Need An Experienced Tax Attorney To Quash IRS Summons!

Ron Marini

A group of taxpayers associated with a limited partnership under audit by the Internal Revenue Service lost their battle against the agency’s summonses for financial information when the U.S. Supreme Court declined to hear their appeal of their Eleventh Circuit loss on Monday.

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Revised Country List For Automatic Exchange Of Information

Ron Marini

In a Rev Proc 2016-56,2016-51 IRB, the IRS has updated two lists of countries with which the U.S. has in effect an agreement that requires payors to report certain deposit interest paid to nonresident alien individuals who are residents of the other country under Reg. § 1.6049-8(a) and Reg. § 1.6049-4(b)(5).

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Argentina Signs Information-Sharing Agreement With The U.S.

Ron Marini

The agreement, in which Argentine officials said they were pursuing in September, is part of a government crackdown on alleged tax evasion by individuals. Argentina also has implemented a tax amnesty plan to recover an estimated $500 million in assets held abroad.

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Court of Appeals Reverses Santander’s Foreign Tax Refund

Ron Marini

The First Circuit Court of Appeals overturned an earlier $234 million victory for Santander Holdings USA Inc. after ruling on December 16, 2016 that an internal securities transaction the bank had engaged in lacked economic substance and does not qualify for foreign tax credits.

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