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Archive for Ronald Marini

Foreign Owned Domestic Disregarded Entities Must Report

Ron Marini

In April 2016, we posted US Pressured For Beneficial Ownership Rules where we discussed a speech by Treasury deputy assistant secretary Jennifer Fowler to a financial crime conference earlier in April noting that the Treasury is in the process of introducing a new rule forcing financial institutions to perform customer due diligence checks on new clients.

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Treasury Releases Their Report On The IRS Whistleblower Program

Ron Marini

We discussed last September that it can take from five to seven years, possibly more, for the IRS Whistleblower Office to make a decision about whether to pay an informant for information about individuals or businesses that don’t pay all of the tax they owe.

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A Holiday Summons A Tale Of Grinches, Princes, Bankers, Toymakers, And Offshore Tax Evasion

Ron Marini

Dave Breen’s, the acting Director of Villanova’s Low Income Taxpayer Clinic, view regarding the case of Greenfield v U.S., which focuses on a recent IRS setback in a summons enforcement case out of the Second Circuit.

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IRS Wins Summons Challenge From Virtual Currency Exchanger Coinbase Inc.

Ron Marini

A California federal court Thursday authorized a John Doe summons by the IRS to obtain information from virtual currency exchanger Coinbase Inc. so it can investigate whether the company’s customers avoided paying taxes on transactions made through the company.

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Panama Papers – Global Effects Thus Far & Continuing Impact

Ron Marini

In April 2016, we posted “Huge Leak From the Panamanian Law Firm Mossack Fonseca!” where we discuss that the offshore planning world was set on fire with the news that 11 million documents were leaked from the Panamanian law firm Mossack Fonseca.

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Set Up Your 2017 Calendar To Reflect New Filing Dates For 2016 U.S. Tax Returns

Ron Marini

On July 31, 2015, President Obama signed into law P.L. 114-41, the “Surface Transportation and Veterans Health Care Choice Improvement Act of 2015,” which includes a number of important tax provisions, including revised due dates for partnership, S corporations and C corporation returns and revised extended due dates for some returns.

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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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