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Archive for Ronald Marini

Summon Rules Applies To Taxpayer’s Marijuana Business

Ron Marini

Colorado- A district court has made several rulings regarding Code Sec. 280E, the Code section that disallows deductions in carrying on a trade or business that consists of trafficking in controlled substances.

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Tax Proposal Including Switch To A Territorial Tax System

Ron Marini, trump, tax proposal

According to a plan released by the White House on April 26, 2017, creating a 15% tax rate for corporations, cutting the top individual tax rate from 39.6% to 35%, reducing the number of rates from seven to three, and repealing a 3.8% tax on net investment income are the top priorities in the Trump administration’s tax reform agenda.

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Proposed 15% Corp. Tax Rate & Repeal of 3.8% Obama Tax

Ron Marini

A 15% tax rate for corporations, cutting the top individual tax rate from 39.6% to 35%, reducing the number of rates from seven to three and the repeal of a 3.8% tax on net investment income are the top priorities in the Trump administration’s tax reform agenda, according to a plan released by the White House today April 26, 2017.

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Corporate Executive Must Face Criminal Charges

Ron Marini

A software and hospitality executive accused of not withholding federal taxes must face criminal charges after the U.S. Supreme Court refused Monday to consider his challenge of a Sixth Circuit decision holding that those charges are not precluded by a civil suit court order forcing him to work without pay.

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1st U.S. Prosecution For False Expatriation Statement

Ron Marini

The IRS has been hunting for offshore income and accounts continues unabated well beyond UBS as evidenced by a former client of Credit Suisse Group AG who pleaded guilty to hiding $200 million from U.S. tax authorities.

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Financial Advisors Are Turning Over Your Names To The IRS

Ron Marini

The Government has added another Financial Advisor since October of 2016, Michael A. Behr, (effective 1/25/17) to their list of Offshore Banks and Foreign Financial Advisors which are turning over the names of their US 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.

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Treasury Lists Countries Requiring Cooperation With Boycott

Ron Marini

The U.S. Treasury Department (Treasury) has published a current list of countries that may require participation in, or cooperation with, an international boycott for purposes of Code Sec. 999, the rule that denies certain tax benefits to a person that participates in or cooperates with an unsanctioned international boycott.

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Private Debt Collection Of Overdue Federal Taxes Starts

Ron Marini

The IRS announced 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. Starting April 2017, the Internal Revenue Service will begin sending letters to a relatively small group of taxpayers whose overdue federal tax accounts are being assigned to one of four private-sector collection agencies.

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Choices for Taxpayers Who Can Not Pay Their Tax Bill(s)

Ron Marini, tax deadline, installment agreements, offer in compromise

As the April 18th deadline for filing 2016 income tax returns draws near, practitioners may encounter some clients who don’t have cash to pay the balance due on their returns. Clients can avoid penalties but not interest if they can get an extension of time to pay from IRS. But such extensions merely postpone the day of reckoning for the period of the extension (generally, six months).

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How A Proposed Cash Flow Tax Could Impact Finance Industry

Ron Marini

The taxation of financial intermediaries has been a perennial problem for the design and administration of VATs. This has required countries around the world to resort to ad hoc solutions that are invariably inefficient and often complex. The House Republican destination-based cash flow tax, which is closely related to a VAT, could be headed down the same uncertain and haphazard path.

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IRS Enforcement Actions Decline 16% In 2016

Ron Marini

The 2016 IRS Data Book describes activities conducted by the IRS from Oct. 1, 2015, to Sept. 30, 2016, and includes information about returns filed, taxes collected, enforcement, taxpayer assistance, the IRS budget and workforce as well as other data. This edition contains charts that show trends such as increases in telephone service and declines in enforcement activities when compared to 2015.

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Possible Phase In Of Any Potential Border Tax Plan

Ron Marini

House Republicans may be bending to political pressure over their most controversial proposal to revamp tax laws, with the leader of the chief tax-writing committee in the House of Representatives saying Wednesday that he is “contemplating significant modifications” to the border-adjusted tax plan. Read more

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