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Archive for Ronald Marini

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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Americans Who Have Renounced Their Citizenship Heading for Record Year

Ronald Marini, Tax Advisor

As many as 1,400 Americans have renounced their citizenship in the third quarter of 2017, according to US Treasury Department data. The trend suggests the total for 2017 will be more than 6,800, which is 26% above the 2016 total and 56% higher than 2015.

Americans are on pace to renounce their citizenship in record numbers in 2017, according to the latest quarterly report from the Treasury Department.

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Offshore Law Firm’s Data Stolen In Cyber Attack, Denies Wrongdoing

Ronald Marini, Tax Advisor

On September 5, 2017, ‘How Will the IRS Know About My Foreign Account?’ was published. In that blog post, we discussed how taxpayers who have financial assets outside the United States often ask the question:

“How will they (IRS) know about my Foreign Account?”

Many ask this when they are considering how (or whether) to come forward and inform the IRS about their previously undisclosed foreign financial accounts.

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What Happened to the IRS OVDP Website?

Ronald Marini, Tax Advisor

Where you represent as many taxpayers as we do in relation to cleaning up their previously undeclared offshore investments and bank accounts, your are on the IRS’ website daily to review the current elements required by the IRS to qualify for an OVDP (Offshore Voluntary Disclosure Program) filing or an OVDP streamline filing.

You can imagine my surprise when my desktop link to each relevant IRS OVDP page, that I’ve been using for the last 8 years no longer worked.

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U.S. Department of the Treasury Amends Eight Tax Regulations Under Obama And Repeals 200 More

 

The U.S. Department of the Treasury  posted it would amend or completely do away with eight tax regulations issued under the Obama administration, including rules regarding corporate debt and transfers of estates, as part of an effort to simplify the tax code.

Treasury also announced that it continues to work to identify additional regulations for modification or repeal by evaluating significant regulations issued recently and initiating a comprehensive review of all regulations, regardless of when they were issued.

The Comprehensive Review has already identified over 200 Regulations that Treasury believes should be repealed which will begin in the Fourth Quarter 2017.

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TIGTA Says That Improvements Are Needed in the IRS’ Estate and Gift Tax Return Examination Process

Ronald Marini, Tax Advisor

The Internal Revenue Service (IRS) needs to make improvements in the classification, prioritization, and inventory assignment processes for the Estate and Gift Tax Return Examination Program, according to an audit report that the Treasury Inspector General for Tax Administration (TIGTA) issued today.

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IRS Budget Cuts Results In Fewer Criminal Tax Investigations

Criminal investigations by the IRS reached their lowest levels over the past five years last year because of a reduction in IRS resources, according to a report by the Treasury Inspector General for Tax Administration.

The office said there were “unfavorable trends” in criminal investigations of businesses due to declining resources, like budget challenges, which resulted in attrition of field special agents, in a report on trends over the past five years that the office made public on September 18, 2017. Read more

IRS Appeals Reverts Back to Face To Face Appeals Conferences

Ron Marini

Internal Revenue Manual (IRM) 8.6.1.4, blandly entitled “Conference Practices,” provides that ALL conferences will be held by telephone except under certain specific enumerated circumstances.

The mission of the IRS Appeals Division is to “resolve tax controversies, without litigation, on a basis which is fair and impartial to both the Government and the taxpayer and in a manner that will enhance voluntary compliance and public confidence in the integrity and efficiency of the Service.”  Read more

How Will the IRS Know About My Foreign Account?

Taxpayers who have financial assets outside the United States often ask the question “How will they (IRS) know about my Foreign Account?” when they are considering how (or whether) to come clean and inform the IRS about their previously undisclosed foreign financial accounts.

For years, there was little public knowledge of the U.S. government’s foreign financial reporting requirements, and enforcement of those rules was not always very strict. However, since 2008, a string of scandals involving foreign banks and investigations by the U.S. government into various non-U.S. financial institutions has garnered international media attention and changed the way governments around the world deal with offshore financial accounts. Read more

IRS Audits – How Are Tax Returns Selected for Audit?

Ron Marini

In order to determine how to respond to an IRS Tax Audit, it is helpful to understand how tax returns are selected for examination. The IRS selects returns for examinations in several ways, some based upon objective criteria coded into a carefully protected computer program and others based upon old fashioned investigation work.

Selection for an IRS Audit does not always suggest there’s a problem. The IRS uses several different methods: Read more

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