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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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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Ronald Marini

We previously posted two articles:

“Your Offshore Confidential Information Is Being Delivered Daily to Tax Authorities – New Leak of Bahamian Offshore Files!” and
“Mossack Fonseca Affected Taxpayers with Potential Exposure Should Consult with Counsel To Consider Their Legal Options Now!”

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This past Friday, December 19, 2014, President Obama signed into law the Tax Increase Prevention Act of 2014 (HR 5771) which passed the the Senate on December 16th, 2014, that retroactively extended certain tax incentives which had expired on December 31, 2013 for one year.

Individual Tax Extenders:

– Research and experimentation credit;
– 50% first-year bonus depreciation;
– Increased expensing limits ($500,000/$2 million) for section 179 property;
– 15-year depreciation life for qualified leasehold improvements, qualified restaurant Read More

For tax year 2015, the Internal Revenue Service announced today annual inflation adjustments for more than 40 tax provisions, including the tax rate schedules, and other tax changes. Revenue Procedure 2014-61 provides details about these annual adjustments.
The tax items for tax year 2015 of greatest interest to most taxpayers include the following dollar amounts –

• The tax rate of 39.6 percent affects singles whose income exceeds $413,200 ($464,850 for married taxpayers filing a joint return), up from $406,750 and $457,600, respectively. The other marginal rates – 10, 15, 25, 28, 33 and 35 percent – and the related income tax thresholds are described in the revenue procedure. Read More

According to Swissinfo, a former top executive at Neue Zürcher Bank (NZB) has turned himself over to the United States justice authorities and may testify in the trial of ex-UBS banker Raoul Weil next week.

We previously posted on December 16, 2013, The 2nd Ex-UBS Banker is About to Blow The Whistle on His US Clients! where we discussed that the former head of UBS’s wealth management division, Raoul Weil, has agreed to be extradited to the US to face charges and U.S. Magistrate Judge Patrick Hunt agreed to let Weil stay with friends in New Jersey after putting up the bond, which included $9 million in a personal surety by Weil, $500,000 from the New Jersey family and the other $1 million a corporate surety bond signed with a bail bondsman. Read More

The IRS recently revised Form 2848, Power of Attorney and Declaration of Representative, and instructions

Among other changes, the new form reflects the 2013 IRS policy change under which the form could no longer be filed electronically and a requirement that certain taxpayer representatives provide a valid preparer tax identification number (PTIN).

According to ThompsonReuters Notable changes to Form 2848 include:

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Since our post of Tuesday, July 1, 2014, 92 FATCA Information Sharing Agreements Start Today! 9 more countries have entered into FATCA agreements with the United States, bringing the total to 101!

Described by the US Government as a “major milestone” on the path to eradicating offshore tax evasion, but branded by its critics as “the worst law that most Americans have never heard of, the Foreign Account Tax Compliance Act (FATCA) went into force on July 1, 2014 after a long period of preparation by the Internal Revenue Service (IRS), foreign revenue agencies and foreign financial institutions (FFIs). Read More

On Thursday, April 28, 2014, we posted “51 FATCA Agreements and Growing!” where we discussed the IRS’ Announcement 2014-17 which provides that countries that have FATCA agreements “in substance” with the United States will be seen as complying with the law, even if the agreements are not finalized by December 31, 2014.

Since then, Australia signed and Israel Reached Agreement on their FATCA agreement, bringing the total to 52 Countries with United States FATCA Agreements!

31 nations with agreements:

1. Australia Read More

On Friday, April 18, 2014, we posted “FATCA Picking Up Momentum And U.S. Gives Foreign Banks More Time to Register”, where we discussed the Internal Revenue Service’s Announcement 2014-17 which provides that countries that have FATCA agreements “in substance” with the United States will be seen as complying with the law, even if the agreements are not finalized by December 31, 2014.

This announcement increased to 48 from 26 the number of countries that have “intergovernmental agreements” (IGAs) with the United States, which allow a country’s financial institutions to comply with FATCA via their domestic regulators. This would include Brazil, South Korea and South Africa, among other countries, who are in the process of negotiating IGA with the US. Read More

Here are some options to consider, even if you can’t pay the full amount right now:

• Borrow the money. If you don’t have the money to pay all your taxes now, then you may want to get a loan from a bank or other source. The interest rate may be lower than the interest and penalties the IRS charges on late taxes. You also may be able to borrow against your assets or sell them to raise cash.

• Make an Online Payment Agreement. If you are unable to pay in full, then consider paying over time.

◦ If you owe $50,000 or less, you can apply for an installment agreement. You may Read More

The Internal Revenue Service has updated Publication 5118 – Foreign Account Tax Compliance Act (FATCA) User Guide (Rev. December 2013) to reflect changes since its initial publication in the summer of 2013.

The User Guide is over 100 pages and provides instructions for completing the registration process online, including the information required, how registration will vary depending on the type of financial institution, and step-by-step guidance for answering each question.

1. The User Guide provides a list of entities that are eligible to register, on behalf of themselves and their branches, and the purposes of such registration (page 8). Read More