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Archive for Ronald Marini

Alert Your Clients To Possible Refund Delays In 2017

Ron Marini

Tax professionals should alert their clients that a new law requires the IRS to hold refunds until mid-February 2017 for people claiming the Earned Income Tax Credit or the Additional Child Tax Credit.

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7th Circuit Court Of Appeal Reduces Options For Appealing IRS Levies

Ron Marini

Rejecting tax court precedent, the Seventh Circuit ruled Friday that delinquent taxpayers who weren’t properly notified of Internal Revenue Service levies still have to pursue an administrative appeal before they can petition the tax court to invalidate the levy.

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Tax Authorities To Have Access to Beneficial Ownership Information By 2018!

The EU Council recently agreed on a proposal granting access for tax authorities to information held by authorities responsible for the prevention of money laundering. The directive will require EU member states to enable access to information on the beneficial ownership of companies. The effective date will apply from January 1, 2018.

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TE/GE Announces New IDR Management Process

Ron Marini

The Tax Exempt and Government Entities Division of the Internal Revenue Service has issued new internal guidance for its agents on issuing information document requests (IDRs). The IRS issues IDRs to gather information during an examination. The new process will go into effect on April 1, 2017. Prior to its implementation, TE/GE will provide training to its agents on the new process.

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New Fast Track Mediation – Collection Procedure 2016-57

Ron Marini

Revenue Procedure 2016-57 replaces Fast Track Mediation (as outlined in Rev. Proc. 2003-41) with Fast Track Mediation—Collection. Revenue Procedure 2016-57 will be in 2016-49, dated December 5, 2016

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Ex-Swiss Banker Heads To Trial For Conspiracy To Evade Taxes

Ron Marini

We posted 144 Offshore Banks & Now Financial Advisors Are Turning Over Your Names To The IRS where we discussed the Government has added 47 more banks and financial advisors to this list bringing the number to 144 total banks and foreign financial advisors. Included in this list as #137 is Stefan Buck (effective 11/15/16).

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Treasury Issues Final & Temporary Section 385 Regs

Ron Marini

As part of the Obama administration’s announcement of a crackdown on inversions the U.S. Treasury issued final and temporary proposed regulations that would dramatically change the taxation of corporate debt issued to related corporations having nothing to do with inversions or foreign acquisitions.

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IRS Un-Resonable In Its Pursuit Of Trust Fund Penalty

A recent U.S. Tax Court case illustrates how aggressive the Internal Revenue Service (IRS) has become in using the trust fund recovery penalty (TFRP) to collect trust fund taxes.

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The Death Of The Estate Tax?

Ron Marini

President-Elect Donald Trump’s tax plans seem to include the repeal of the U.S. Estate & Gift taxes. This may be a realistic possibility considering that some of the proposals in the Republican House Ways & Means Committee Report of June 24, 2016 mention the repeal and Republicans now have control over Congress.

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IRS Does Not Have Sufficient Funding To Handle Transfer Pricing

Ron Marini

The IRS lacks the resources to enforce anti-tax avoidance measures targeted at offshore transfer pricing schemes, the agency has said in response to a watchdog report on the subject.

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10 States That Provide The Most Protections For Dynasty Trusts

Ron Marini

Protecting wealth for future generations is often the goal for those who have been financially successful in life. A wealthy family founding father (or mother) can create a dynasty trust which is a long-term trust that can last varying amounts of time, depending on state law. It is irrevocable, meaning once it is funded the grantor or succeeding trustees cannot change it.

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Swiss Bank Rats Out NYU Business Professor – Results in Fine of $100M & Up To 5 Yrs in Prison

John Dundon

We previously posted October 15, 2016—144 Offshore Banks & Now Financial Advisors Are Turning Over Your Names To The IRS – What Are Your Waiting For?—where we discuss that there are 144 offshore banks and financial advisors that are turning your names over to the IRS as part of their deferred prosecution agreements. Below is the story about one US citizen who had accounts with one of these banks and how he is now being criminally prosecuted for not addressing his previously undeclared foreign income.

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