In Legal Advice Issued by Associate Chief Counsel 2016-004, the IRS has given its opinion on the exact moment when information that it provides to and receives from foreign tax administrations via the Organization for Economic Cooperation and Development’s Common Transmission System becomes protected under the Code’s confidentiality rules. Legal Advice Issued by Associate Chief Counsel 2016-004.
Archive for Ronald Marini
During my Estate Planning Attorney’s 30+ years as a senior attorney at the IRS and his subsequent career as a tax consultant, he has seen an ongoing struggle over the rate of tax to be imposed on estates. Generally, this ebb and flow has pitted Republican Party attempts to eliminate the estate tax vs. the Democratic Party’s attempts to increase the estate tax rate.
144 Offshore Banks & Now Financial Advisors Are Turning Over Your Names To The IRS – What Are Your Waiting For?
On May 26, 2016 we posted 97 Offshore Banks Are Turning Over Your Names To The IRS – What Are Your Waiting For? and since then, the Government has added 47 more banks and financial advisors to this list bringing the number to 144 offshore banks and foreign financial advisors. The IRS keeps updating its list of foreign banks which are turning over the names of their U.S. Account Holders, who are now subject to a 50% (rather than 27.5%) penalty in the IRS’s Offshore Voluntary Disclosure Program (OVDP). This penalty is based on the highest account balance measured over up to eight years.
According to The New York Times, Warren E. Buffett, the billionaire investor, volunteered more detailed information about his income taxes than Donald J. Trump, the Republican nominee, ever has.
We previously posted More fallout from the “Panama Papers” – Commercial Bank of Taiwan To Pay a $180 Million Penalty we where we discussed that Financial Services Superintendent Maria T. Vullo announced on 8/19/16 that Mega International Commercial Bank of Taiwan will pay a $180 million penalty and install an independent monitor for violating New York’s anti-money laundering laws.
A new report released this week by Citizens for Tax Justice (CTJ), the Institute of Taxation and Economic Policy (ITEP) and the US Public Interest Research Group (PIRG) posits that Fortune 500 (US-based) companies have stashed away close to $2.5 trillion in offshore accounts in an effort to reduce their tax burdens.
Revenue Procedure 2016-49 provides procedures to disregard and treat as null and void for transfer tax purposes a qualified terminable interest property (QTIP) election in situations where the QTIP election was not necessary to reduce the estate tax liability to zero.
Europe Begins Inquiry Into ‘Panama Papers’ & ‘Bahamian Papers’ – How Long Before You Are Discovered?
We previously posted two articles:
“Your Offshore Confidential Information Is Being Delivered Daily to Tax Authorities – New Leak of Bahamian Offshore Files!” and
“Mossack Fonseca Affected Taxpayers with Potential Exposure Should Consult with Counsel To Consider Their Legal Options Now!”
The Internal Revenue Service announced today that it plans to begin private collection of certain overdue federal tax debts next spring and has selected four contractors to implement the new program.
In this presidential election, the Republican candidate Donald Trump steadfastly refuses to release his tax returns. This has caused political blogs to have a lively discussion regarding whether President Obama could request Donald Trump’s tax returns from the Internal Revenue Service (IRS)?