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Archive for Ronald Marini

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The Comprehensive Review has already identified over 200 Regulations that Treasury believes should be repealed which will begin in the Fourth Quarter 2017.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

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.  Read more

New E-Business Visa Route For Frustrated Foreign Investors

Citizenship applications for the Caribbean island of Grenada have boomed in the last three years.

Reports have emerged that Grenada’s citizenship by investment program, introduced in 2014, is being used to fast-track U.S. E2 visa applications. Read more

All That You Wanted to Know About Form 706NA – Part I

Deceased nonresidents who were not American citizens are subject to U.S. estate taxation with respect to their U.S.-situated assets. Also, many foreigners owning property or assets in the United States are in violation of 706-NA filing requirements because of a number of misunderstandings. The basic rule is pretty clear-if a foreign decedent has assets in the United States with a gross value in excess of $60,000, the estate is supposed to file a tax return with the Internal Revenue Service.  Read more

Ireland Disagrees With EU’s Decision To Collect €13 Billion

Ireland previously has said it planned to shut down a much-criticized tax arrangement used by Apple Inc. to shelter over $40 billion from taxation, but will leave open an even bigger loophole that means the computer giant is unlikely to pay any more tax. The highly criticized arrangement has become known in the tax avoidance industry as the “double Irish”. This arrangement has been used by Google, Microsoft & Apple, just to name a few.  Read more

Issues Concerning Filing A Form 706-NA

Deceased nonresidents who were not American citizens are subject to U.S. estate taxation with respect to their U.S.-situated assets.

Many foreigners owning property or assets in the United States are in violation of 706-NA filing requirements because of a number of misunderstandings. The basic rule is pretty clear-if a foreign decedent has assets in the United States with a gross value in excess of $60,000, the estate is supposed to file a tax return with the Internal Revenue Service.  Read more

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