Archive for Ronald Marini

Beneficial Ownership Register Starting July 1st

Ron Marini

The British Virgin Islands’ Government signed new legislation regarding Beneficial Ownership & Technical Protocol with the UK which will come into force in June 2017, which is hoped to improve the exchange of beneficial ownership information between the UK& BVI law enforcement for taxation rulings. Read more

U.S. Tax Planning After BEPS

Ron Marini

Previously, we discussed that more than 100 jurisdictions have concluded negotiations on a multilateral instrument(MLI) that will swiftly implement a series of tax treaty measures to update international tax rules and lessen the opportunity for tax avoidance by multinational enterprises.

Even though the U.S. participated in the negotiations over the MLI, it ultimately chose not to adopt the convention.

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U.S. Now Revoking Passports of Taxpayers With Unpaid Taxes!

Ron Marini

The tax code now provides for authorities to revoke or deny the passport of any U.S. taxpayer who has unpaid taxes in excess of $50,000 or who have not obtained or won’t provide a Social Security numbers. The IRS updated it website to state that the IRS had not yet started certifying tax debt to the State Department. However, Certifications to the State Department will begin in early 2017 and this webpage will be updated to indicate when this process has been implemented. Read more

IRS Targeting Foreign Corporations Which Do Not File!

Ron Marini

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. Read more

Lessons For U.S. Taxpayers Hiding Assets Offshore

Ron Marini

Argentine soccer superstar Lionel Messi was sentinced to 21 months in jail after he was found guilty of tax fraud for using offshore companies to avoid paying Spanish taxes on advertising contracts. Read more

Due to Court Ruling IRS PTIN System Down

On June 1, 2017, the United States District Court for the District of Columbia upheld the Internal Revenue Service’s authority to require the use of a Preparer Tax Identification Number (PTIN), but enjoined the IRS from charging a user fee for the issuance and renewal of PTINs. Read more

Offshore Insurance Wrapper Holding Your Foreign Wealth?

When asked “With the success of the Swiss Bank Program, have there been plans to announce a similar initiative?” Former DOJ Tax Head Caroline Ciraolo responded by saying that when she left the DOJ earlier this year, the department wasn’t planning to announce another offshore program. “A part of the reason was because of the Success of the Swiss Bank Program,” she said. Read more

What To Do When You Receive An IRS Notice?

Ron Marini

The IRS sends many, many, many, letters and correspondence before they levy or garnished any taxpayer’s wages, bank accounts, or other assets. Many taxpayers take the ostrich approach and ignore the problem, in hopes that it will go away.

If you’re facing an IRS Problem, appropriate action can go a long way towards resolving it! Read more

Multilateral Convention To Implement Tax Treaties

Ron Marini

More than 100 jurisdictions have concluded negotiations on a multilateral instrument that will swiftly implement a series of tax treaty measures to update international tax rules and lessen the opportunity for tax avoidance by multinational enterprises. Read more

Offshore Tax Suit Switch From OVDP Doesn’t Block Collection

Ron Marini

Three taxpayers seeking to switch over to the IRS’ new “streamlined” compliance program for unreported offshore income argued to a D.C. Circuit panel Tuesday that their lawsuit is not foreclosed by the Anti-Injunction Act’s bar on pre-enforcement tax challenges, attacking the government’s key defense in the case. The case is Maze et al. v. Internal Revenue Service et al., case number 16-5265, in the U.S. Court of Appeals for the District of Columbia Circuit.

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A Year Later, Mixed Fortunes For Panama Papers Line-Up

Ron Marini

When the International Consortium of Investigative Journalists and more than 100 media partners began publishing the Panama Papers investigation on April 3, 2016, almost no country was untouched by its revelations.

Governments in more than 70 Countries have launched over 150 Investigations, Inquiries, Audits and Probes into the affairs of Thousands of People and Corporations linked to Notorious “Panama Papers.”

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How To Get The IRS To Accept Your Offer In Compromise

Do you owe a substantial amount of taxes to the IRS?

If so, you’ve likely looked into establishing a payment plan.

What if you are simply unable to pay your tax balance?

In this case, you might consider requesting an offer in compromise, which is a last-resort option that allows you to settle your account for literally pennies on the dollar.

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