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Archive for Ronald Marini

IRS Needs To Improve Its Offer In Compromise Process

Ron Marini

Internal Revenue Service has taken steps to improve the offer in compromise process for both taxpayers and the IRS, but it can still do more, according to a new report.

An offer in compromise is an agreement between a taxpayer and the IRS that settles a tax liability for a payment of less than the full amount owed.

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TIGTA Report Concludes That IRS’s Lax Enforcement Is Costing $9 Billion

Ron Marini

The Treasury Inspector General for Tax Administration (TIGTA) issued a report concluding that the IRS’s lax enforcement of backup withholding requirements is potentially causing billions of dollars in lost revenue (TIGTA Rep’t No. 2016-40-078).

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IRS Targets Nonfilers To Aid In Collecting Billions In Taxes

Ron Marini

A report from the Treasury Inspector General for Tax Administration (TITGA) said the IRS has a strategy in place as part of its Case Creation Nonfiler Identification Process to identify taxpayers who have not filed a tax return and are required to do so if their income is above a certain threshold. The IRS typically issues delinquency notices to more than 640,000 nonfilers each year whose tax extensions have expired.

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OVDP Does Not Cause Green Card Holders To Be Deported

Ron Marini

A few years back, we discussed that the U.S. Supreme Court decision on February 21, 2012 decided that lawful permanent residents who have pled guilty to charges related to the filing of false tax returns that resulted in a loss to the government of more than $10,000 have committed aggravated felonies involving fraud or deceit and are subject to deportation (Kawashima v. Holder, U.S., No. 10-577, 2/21/12).

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Streamlined Processing Of Installment Agreements

Ron Marini

The IRS is testing expanded criteria for streamlined processing of taxpayer requests for installment agreements. The test is scheduled to run through September 30, 2017.

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IRS Nets $10 Billion From More Than 100,000 Taxpayers In The OVDP Programs

Ron Marini

The IRS, in news release IR 2016-137, highlighted the accomplishments of its Offshore Voluntary Disclosure Program (OVDP) and encouraged taxpayers with undisclosed offshore accounts to come into compliance with the federal tax obligations. The OVDP and streamlined compliance programs have been used to bring over 100,000 taxpayers into compliance and have brought in over $10 billion in taxes, interest, and penalties.

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IRS Provides Legal Advice When Data Exchange With Foreign Countries is Confidential

Ronald Marini

In Legal Advice Issued by Associate Chief Counsel 2016-004, the IRS has given its opinion on the exact moment when information that it provides to and receives from foreign tax administrations via the Organization for Economic Cooperation and Development’s Common Transmission System becomes protected under the Code’s confidentiality rules. Legal Advice Issued by Associate Chief Counsel 2016-004.

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The President That You Elect Could Impact Your Estate Taxes

Ronald Marini

During my Estate Planning Attorney’s 30+ years as a senior attorney at the IRS and his subsequent career as a tax consultant, he has seen an ongoing struggle over the rate of tax to be imposed on estates.  Generally, this ebb and flow has pitted Republican Party attempts to eliminate the estate tax vs. the Democratic Party’s attempts to increase the estate tax rate.

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144 Offshore Banks & Now Financial Advisors Are Turning Over Your Names To The IRS – What Are Your Waiting For?

Ron Marini

On May 26, 2016 we posted 97 Offshore Banks Are Turning Over Your Names To The IRS – What Are Your Waiting For? and since then, the Government has added 47 more banks and financial advisors to this list bringing the number to 144 offshore banks and foreign financial advisors. The IRS keeps updating its list of foreign banks which are turning over the names of their U.S. 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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Buffett Releases His Tax Data To Rebut Trump

According to The New York Times, Warren E. Buffett, the billionaire investor, volunteered more detailed information about his income taxes than Donald J. Trump, the Republican nominee, ever has.

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More And More Fallout From the “Panama Papers”!

Ron Marini

We previously posted More fallout from the “Panama Papers” – Commercial Bank of Taiwan To Pay a $180 Million Penalty we where we discussed that Financial Services Superintendent Maria T. Vullo announced  on 8/19/16 that Mega International Commercial Bank of Taiwan will pay a $180 million penalty and install an independent monitor for violating New York’s anti-money laundering laws.

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Good Corporate U.S. Tax Planning Gone Awry?

Ron Marini

A new report released this week by Citizens for Tax Justice (CTJ), the Institute of Taxation and Economic Policy (ITEP) and the US Public Interest Research Group (PIRG) posits that Fortune 500 (US-based) companies have stashed away close to $2.5 trillion in offshore accounts in an effort to reduce their tax burdens.

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