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Tag Archive for Ronald Marini

TaxConnections Worldwide Tax Blogs Honors Ronald Marini

Kat Jennings

Every week, until the end of the year, we will be celebrating one of our top writers on TaxConnections.

This week we are honoring Ronald Marini.

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Argentina and Barcelona Soccer Player Leo Messi Handed Jail Term In Spain For Tax Fraud

Ron Marini

On July 6, 2016, a Spanish court sentenced the Argentine soccer superstar Lionel Messi to 21 months in jail after he was found guilty of tax fraud for using offshore companies to avoid paying Spanish taxes on advertising contracts.

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The IRS Issues New Version of Form W-8 BEN-E

Ronald Marini

 

On December 17, 2014 we posted How to Complete Form W-8 BEN E & and W-8IMY? where we discussed how to fill out the various Form W–8’s, which now has increased to 8 pages in some cases.

This post provided foreign entities a set of step-by-step instructions to complete the new Forms W-8BEN-E and W-8IMY, as well as a general overview of the obligations imposed on foreign financial institutions under the new chapter 4 FATCA regime including: Read more

DoJ Launches Criminal Investigation of Hundreds of US Taxpayers

Ronald Marini

On April 4, 2016 we posted Huge Leak From the Panamanian Law Firm Mossack Fonseca! where we discussed 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.  They allegedly show how Mossack Fonseca has helped clients launder money, dodge sanctions and evade tax.

This post also speculated that U.S. persons will probably show up, Read more

IRS issues Final Form 8971 & Instructions on How To Report the Final Estate Tax Value of a Property Transfered to Beneficiaries

ronmarini2

For many years the IRS has had a problem verifying the basis of assets received by an heir from an estate. Within the last three or four years, the IRS has required brokerage houses and banks to supply it with the cost basis so that it could determine that the capital gain or loss on securities was correctly calculated.

There was no such parallel form within the estate tax forum. Section 1014 of the IRC gives the heirs a basis equal to a value reported on an estate tax return. Later, if an heir sells the inherited property, there is no transitional method for the IRS to Read more

U.S FinCEN Will Track Secret Buyers of Luxury Real Estate in Manhattan and Miami

Ronald Marini

The Financial Crimes Enforcement Network (FinCEN) today January 13, 2016 issued a Geographic Targeting Orders (GTO) that will temporarily require certain U.S. title insurance companies to identify the natural persons behind companies used to pay “all cash” for high-end residential real estate in the Borough of Manhattan in New York City, New York, and Miami-Dade County, Florida.

FinCEN is concerned that all-cash purchases – i.e., those without bank financing – may be conducted by individuals attempting to hide their assets and identity by purchasing residential properties through limited liability companies or other opaque structures. To enhance availability of information pertinent to mitigating this potential money laundering vulnerability, FinCEN will require certain title insurance companies to identify and report the true “beneficial owner” behind a legal entity involved in certain high-end residential real estate transactions in Manhattan and Miami-Dade County.
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IRSAC Releases Its 2015 Annual Report

Ronald Marini picture36

Internal Revenue Service Advisory Council (IRSAC) held its annual public meeting this week and released its annual report for 2015 to the IRS Commissioner. The report includes recommendations on a wide range of tax administration issues.

The IRSAC is an advisory group to the entire agency. The IRSAC’s primary purpose is to provide an organized public forum for the Commissioner, senior IRS executives and representatives of the public to discuss relevant tax administration issues.

“Members of IRSAC volunteer their time and energy to provide us with valuable feedback and suggestions regarding the most important issues affecting all types of taxpayers,” said IRS Commissioner John Koskinen. Read more

Tax Delinquents May Have Passports Cancelled – Take 2!

Ronald Marini picture34

We previously posted on Thursday, May 31, 2012 Tax Delinquents May Have Passports Canceled & Be Questioned at Air & Sea Ports  where we discussed that almost unnoticed, Congress is close to approving a law under which the Internal Revenue Service (IRS) will be able to revoke the passports of Americans who owe substantial unpaid taxes. Nothing has happened until now.

A GAO report found that for the 2008 tax year, the State Department issued passports to more than 224,000 citizens who owed about $6 billion in tax. Most of it was for individual income taxes, and nearly two-thirds was more than three years old.  The biggest Tax Debtor owed $46.6 million and was part-owner of a professional sports team. Another owed nearly $40 million and had traveled to 10 foreign countries in the recent past. The report said that the IRS had filed tax liens against both individuals but large amounts of tax Read more

Finally The Senate Foreign Relations Committee Approves 8 Tax Treaties!

Ronald Marini picture32

We previously posted on November 2, 2015, Republican and Democratic Lawmakers Vow to Push Tax Treaties Delayed by Sen. Paul! where we discussed that over a year ago, we posted U.S. Senator Rand Paul Continues To Block 5 Important Tax Treaties where we discussed that the U.S.-Switzerland tax treaty remains stuck in the Senate after Sen. Rand Paul (R-Ky.) blocked an effort to propel it forward by Senate Foreign Relations Committee Chairman Robert Menendez (D-N.J.) When a bipartisan Senate panel lambasted Swiss bank Credit Suisse for helping rich Americans evade billions in taxes, some watching the high-profile hearing couldn’t help but notice that Sen. Rand Paul sticks out like a elephant in the room. Senator Rand Paul on Wednesday June 4, 2014 again blocked the U.S. Senate from moving toward ratifying five pending tax treaties, saying they would make it easier for foreign governments to invade the privacy of Americans. Now Treaties with: Read more

Unprecedented Success for US Offshore Amnesty Programs!

Ronald Marini picture31

According to the Internal Revenue Service:

Since OVDP Began in 2009, There Have Been > 54,000 Disclosures!
The IRS has collected > $8 Billion.

We previously discussed this in our post “Offshore Compliance Programs Generate $8 Billion” However, the figures have risen sharply since the IRS’ last progress report in January this year, when it announced that the OVDP schemes had attracted 54,000 disclosures and USD7 billion in tax.

It is believed that most of the additional 30,000 taxpayers who have volunteered since then, have been attracted by the ‘streamlined’ program launched in June 2014 for ‘non-wilful’ taxpayers. This program originated from the IRS’ Read more

OECD To Release BEPS Package To Stop Tax Avoidance!

Ronald Marini picture13

The OECD will release the final package of measures for a coordinated international approach to reform the international tax system under the OECD/G20 Base Erosion and Profit Shifting (BEPS) strategy to tackle tax avoidance by multinational companies on Monday October 5, 2015.

The final outcomes of the BEPS Project will be presented by Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration, during a webcast news conference at 2:00 p.m. (CET).

A technical briefing via webcast on the BEPS deliverables will follow, at 4:00 p.m. (CET).

The OECD/G20 BEPS Project provides governments with clear international solutions to Read more

Oh Oh, We Are Half Way There … 50 Swiss Banks Are Turning Over Their US Client’s Names

Ronald Marini picture9

The number of Swiss banks that have entered deferred prosecution agreements with the U.S. government keeps growing. The IRS keeps updating its list of foreign banks where the holders of these offshore accounts are 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.

On September 17, 2015 we posted “48 Swiss Banks Are Turning Over Their US Client’s Names”, well make that 50 now. The IRS recently added St. Galler Kantonalbank AG (SGKB) and E. Gutzwiller & Cie, Banquiers on 9/17/15. The complete list is as follows, as of 9/17/15: Read more

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