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Archive for Ronald Marini

Due to Court Ruling IRS PTIN System Down

On June 1, 2017, the United States District Court for the District of Columbia upheld the Internal Revenue Service’s authority to require the use of a Preparer Tax Identification Number (PTIN), but enjoined the IRS from charging a user fee for the issuance and renewal of PTINs. Read more

Offshore Insurance Wrapper Holding Your Foreign Wealth?

When asked “With the success of the Swiss Bank Program, have there been plans to announce a similar initiative?” Former DOJ Tax Head Caroline Ciraolo responded by saying that when she left the DOJ earlier this year, the department wasn’t planning to announce another offshore program. “A part of the reason was because of the Success of the Swiss Bank Program,” she said. Read more

What To Do When You Receive An IRS Notice?

Ron Marini

The IRS sends many, many, many, letters and correspondence before they levy or garnished any taxpayer’s wages, bank accounts, or other assets. Many taxpayers take the ostrich approach and ignore the problem, in hopes that it will go away.

If you’re facing an IRS Problem, appropriate action can go a long way towards resolving it! Read more

Multilateral Convention To Implement Tax Treaties

Ron Marini

More than 100 jurisdictions have concluded negotiations on a multilateral instrument that will swiftly implement a series of tax treaty measures to update international tax rules and lessen the opportunity for tax avoidance by multinational enterprises. Read more

Offshore Tax Suit Switch From OVDP Doesn’t Block Collection

Ron Marini

Three taxpayers seeking to switch over to the IRS’ new “streamlined” compliance program for unreported offshore income argued to a D.C. Circuit panel Tuesday that their lawsuit is not foreclosed by the Anti-Injunction Act’s bar on pre-enforcement tax challenges, attacking the government’s key defense in the case. The case is Maze et al. v. Internal Revenue Service et al., case number 16-5265, in the U.S. Court of Appeals for the District of Columbia Circuit.

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A Year Later, Mixed Fortunes For Panama Papers Line-Up

Ron Marini

When the International Consortium of Investigative Journalists and more than 100 media partners began publishing the Panama Papers investigation on April 3, 2016, almost no country was untouched by its revelations.

Governments in more than 70 Countries have launched over 150 Investigations, Inquiries, Audits and Probes into the affairs of Thousands of People and Corporations linked to Notorious “Panama Papers.”

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How To Get The IRS To Accept Your Offer In Compromise

Do you owe a substantial amount of taxes to the IRS?

If so, you’ve likely looked into establishing a payment plan.

What if you are simply unable to pay your tax balance?

In this case, you might consider requesting an offer in compromise, which is a last-resort option that allows you to settle your account for literally pennies on the dollar.

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Automatic Exchange of Information Reporting Is Imminent!

HMRC has reminded financial institutions that the deadline for reporting their clients’ accounts under the Automatic Exchange of Information rules falls in less than a week’s time. Returns must be submitted by May 31, 2017, including reportable accounts for the U.S. Foreign Account Tax Compliance Act (FATCA), Crown Dependencies and Overseas Territories agreement, and the first year for the OECD’s Common Reporting Standards.

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Big Businesses Lobby For 3.5% Offshore Repatriation Tax

Ron Marini

According to various news reports, U.S. multinationals are “pushing” the U.S. government to further reduce the tax rate on offshore profits. Major U.S. multinationals are pushing the Trump administration to deepen the tax break it has already tentatively proposed on $2.6 trillion in corporate profits being held offshore by more than 500 U.S. companies.

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Tax Reform Dead? No Plan B Without Border Tax?

Ron Marini

Previously, we discussed the that the most realistic baseline scenario regarding tax legislation is that there is a repeal of the ACA and associated taxes. While at this time, it is unclear what a replacement bill may look like.

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The OVDP Program May End After 2017

Ron Marini

U.S. taxpayers who have foreign bank and/or financial accounts should be watching the clock. The window to voluntarily report foreign accounts in order to mitigate IRS penalties may be ending after 2017.

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Are You Hiding Assets In The BVI?

Ron Marini

The British Virgin Islands’ Government has signed new legislation regarding Beneficial Ownership & Technical Protocol with the UK which will come into force in June 2017, which is hoped to improve the exchange of beneficial ownership information between the UK & BVI law enforcement for taxation rulings.

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