Archive for Ronald Marini

Mossack Fonseca Closing At End Of March!

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

Mossack Fonseca, the firm at the center of the ‘Panama Papers’ affair, has announced it is to close operations at the end of March 2018.

Millions of confidential client documents were stolen from the trust and company service provider in April 2016 and released to the press, triggering a media campaign that led to reputational deterioration and raids on its offices by Panamanian authorities.

At least 150 investigations were opened in 79 countries to examine possible tax evasion and money laundering, according to the US-based Center for Public Integrity. Read more

Taxpayers Who Owe Taxes Have Multiple Payment Options

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

The Internal Revenue Service reminded taxpayers that there are several easy options to pay taxes electronically. For those unable to pay on time, the IRS offers a variety of ways to take care of a tax liability.

This is the fifth in a series of nine IRS news releases called the TaxTime Guide, designed to help taxpayers navigate common tax issues.

This year’s tax-filing deadline is April 17. Taxpayers who owe taxes can choose among the following quick and easy electronic payment options: Read more

Good Luck Trying To Call The IRS!

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

The IRS will receive more than 95 million calls this year. They expect to answer about 60% of them during the current filing season. After that, the number is estimated to decline to 40%.  Figure in the calls with questions about the new tax law and the answer rate may be even lower. And that projection was made before lawmakers rewrote the tax code in December.

The number of calls is likely to spike, if prior tax law changes are any indication. After Congress passed economic stimulus legislation in 2008, the IRS was “deluged” with more than 150 million telephone calls from taxpayers, a 125 percent increase from the previous year, according to the report.

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IRS Issues FAQ’s Regarding How To Report Section 965 Transition Tax On 2017 Tax Returns

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

On March 13, 2018, the IRS added Questions and Answers about Reporting Related to Section 965 on 2017 Tax Returns on its website.

This document provides answers to questions regarding return filing and tax payment obligations arising under Section 14103 of “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018,” P.L 115-97 (“the Act”), which was enacted on December 22, 2017. Read more

Corporate Tax Cuts Mostly Going To Share Buybacks Not JOBS

Ronald Marini, Tax Advisor, Tax Blog, Miami, Florida, USA, TaxConnections
While the name of the 2017 Tax Act was “Tax Cuts and Jobs Act,” it doesn’t appear like the corporate tax cuts are creating many US Jobs.
The Tax Cuts and Jobs Act was supposed to spur hiring and investment at companies as the maximum corporate tax rate was slashed from 35 to 21 percent, according to Republican proponents. But Democrats point to evidence that many major corporations are instead using the savings to buy back their own stock.

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1st Taxpayer Victory In A “Willful” FBAR Penalty Case

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

On September 20, 2017, the Eastern District of Pennsylvania issued an important taxpayer friendly opinion regarding the willfulnessstandard in FBAR penalty matters.

In Bedrosian v. United States, Case No. 2:15-cv-05853-MMB (E.D. Pa., Sept. 20, 2017), the court held that the government had not met its burden in proving that Bedrosian had willfully violated FBAR reporting requirements.

This opinion could have a major effect on future IRS decisions in the offshore compliance arena and may cause some taxpayers, to seek a more aggressive approach in addressing prior non-compliance. Read more

IRS To End OVDP Sept. 28 – Last Chance For Taxpayers With Undisclosed Foreign Assets

Ronald Marini, Tax Advisor, Tax Blog, Miami, Florida, USA, TaxConnections
WASHINGTON – The Internal Revenue Service today announced (IR-2018-52) that it will begin to ramp down the 2014 Offshore Voluntary Disclosure Program (OVDP) and close the program on Sept. 28, 2018.
By alerting taxpayers now, the IRS intends that any U.S. taxpayers with undisclosed foreign financial assets have time to use the OVDP before the program closes.

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Apple’s Lobbying Saved Them $47 Billion In IRS Taxes

Ronald Marini, Tax Advisor, Miami, Florida, USA, TaxConnections
On January 18, 2018 we posted Apple to pay $38 Billion in Repatriation Taxes where we discussed that Apple 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.
Now the ICIJ analyzes this decision by Apple to bring back hundreds of billions of dollars in offshore cash claiming a “responsibility to give back” to the United States.
Prior to the TCJA of 20107 change, many big corporations were achieving astonishingly low worldwide tax rates and amassing mountains of cash offshore. Some estimates suggest as much as $2.8 trillion has been locked in this offshore limbo. And no multinational has been better at the avoidance game than Apple.

Read more

Trump To Name Tax Lawyer Rettig As IRS Commissioner

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

Trump plans to nominate tax lawyer Charles “Chuck” Rettig as IRS commissioner, Politico reported.

  • If confirmed, Rettig will oversee implementation of the Tax Cuts and Jobs Act.
  • Rettig previously served as the chair of the IRS Advisory Council

He will also have to deal with an agency weakened by sharply reduced staffing after budget cuts by Republican lawmakers in recent years. The IRS has lost more than 17,000 employees, almost 20 percent of its staff, since 2010. Read more

TV Star Michael “The Situation” Sorrentino Pled Guilty In $8.9 Million Tax Case

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

According to Law360 “Jersey Shore” star Michael “The Situation” Sorrentino and his brother Marc Sorrentino have agreed to plead guilty in their criminal case over tax-related charges instead of going to trial next month, according to a government letter on January 17, 2018 to a New Jersey federal judge.

The parties told the court Tuesday that the Sorrentinos had agreed to plead guilty, and U.S.District Judge Susan D. Wigenton scheduled a hearing for Friday for the defendants to enter their guilty pleas, according to a one-page letter prosecutors sent the judge Wednesday. The parties thus asked Judge Wigenton in the letter to stay a Wednesday deadline outlined in parts of a scheduling order entered in connection with the brothers’ upcoming trial. Read more

IRS To Begin Revoking US Passports Of Delinquent Taxpayers In 2018

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

Starting this month, the IRS will start implementing new procedures required under a 2015 law to crack down on individuals with “seriously delinquent tax debts.”

The IRS issued Notice 2018-1 on January 16, 2018, which provides guidance for implementation of the new IRC 7345, added by Section 32101 of the FAST Act. Upon receipt of section 7345 certification, the State Department is generally required to deny a passport application for individuals with seriously delinquent tax debts and may also revoke or limit passports previously issued to those individuals. The notice also describes some exceptions to certification and taxpayer remedies.  Read more

You Cannot Deduct The Cost Of Building Your House As A Business Expense

According to the Department of Justice, the former President and CEO of Pennsylvania health services management company was indicted by a federal grand jury in Pittsburgh on February 13, 2018 for conspiring to defraud the United States and filing fraudulent income tax returns.

According to the indictment, Joseph W. Nocito was CEO of Automated Health Systems Inc. (AHS), a Pittsburgh – based company that administered public health programs for state and local governments. The indictment alleges that Nocito conspired with others to defraud the Internal Revenue Service by fraudulently claiming millions of dollars of personal expenses as corporate business expenses Including:

  1. Construction of his 39,000 square foot home in Sweickley which Nocito refers to as ” Villa Noci”.
  2. Payments on a Jaguar, Maserati and Rolls Royce.
  3. Personal Butler; Personal Cook and Country Club Memberships.

Nocito is also charged with understating his income on his personal taxes by not reporting the income he diverted for personal expenses. The indictment further alleges that Notico concealed millions in taxable profits of AHS by shuffling millions in payments between AHS and other companies Nocito owned, such as Northland Properties, Golden Triangle Leasing, Management Financial Services, in order to fraudulently deduct the payments as business expenses and reduce the tax liability of AHS.

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