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Archive for Ronald Marini

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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Recklessness = Willful Failure To File FBAR

Ron Marini

A district court has found that the taxpayers’ failure to timely file a Foreign Bank and Financial Accounts Report (FBAR) was willful where, among other things, they stopped employing a bookkeeper or keeping any books after opening a foreign bank account and made several misrepresentations under penalty of perjury when they applied to participate in IRS’s Offshore Voluntary Disclosure Program (OVDP).

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Foreign Owned Domestic Disregarded Entities Must Report

Ron Marini

In April 2016, we posted US Pressured For Beneficial Ownership Rules where we discussed a speech by Treasury deputy assistant secretary Jennifer Fowler to a financial crime conference earlier in April noting that the Treasury is in the process of introducing a new rule forcing financial institutions to perform customer due diligence checks on new clients.

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Treasury Releases Their Report On The IRS Whistleblower Program

Ron Marini

We discussed last September that it can take from five to seven years, possibly more, for the IRS Whistleblower Office to make a decision about whether to pay an informant for information about individuals or businesses that don’t pay all of the tax they owe.

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A Holiday Summons A Tale Of Grinches, Princes, Bankers, Toymakers, And Offshore Tax Evasion

Ron Marini

Dave Breen’s, the acting Director of Villanova’s Low Income Taxpayer Clinic, view regarding the case of Greenfield v U.S., which focuses on a recent IRS setback in a summons enforcement case out of the Second Circuit.

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IRS Wins Summons Challenge From Virtual Currency Exchanger Coinbase Inc.

Ron Marini

A California federal court Thursday authorized a John Doe summons by the IRS to obtain information from virtual currency exchanger Coinbase Inc. so it can investigate whether the company’s customers avoided paying taxes on transactions made through the company.

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Panama Papers – Global Effects Thus Far & Continuing Impact

Ron Marini

In April 2016, we posted “Huge Leak From the Panamanian Law Firm Mossack Fonseca!” where we discuss that the offshore planning world was set on fire with the news that 11 million documents were leaked from the Panamanian law firm Mossack Fonseca.

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Set Up Your 2017 Calendar To Reflect 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.

Read more

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