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Tag Archive for Ronald Marini

Canadian Court Allows Extradition Of Tax Shelter Promoter

Ronald Marini, Tax Connections

A Canadian court has granted the U.S. government’s request to extradite a tax attorney who is facing charges back home accusing him of helping former partners of Ernst & Young LLP develop and market fraudulent tax shelters, while dodging more than $8 million in taxes himself. A Canadian court has granted the U.S. government’s request to extradite a tax attorney who is facing charges back home accusing him of helping former partners of Ernst & Young LLP develop and market fraudulent tax shelters, while dodging more than $8 million in taxes himself. Read more

Senate Passes $1.4 Trillion Tax Cut Legislation

Ronald Marini, Tax Advisor

According to Law360, The U.S. Senate passed an expansive tax cut bill early Saturday that is projected to add more than $1 trillion to the deficit, after garnering enough support from faltering and fiscally conservative Republicans.According to Law360, The U.S. Senate passed an expansive tax cut bill early Saturday that is projected to add more than $1 trillion to the deficit, after garnering enough support from faltering and fiscally conservative Republicans. The Tax Cuts and Jobs Act, or H.R. 1, passed by a vote of 51-49, with Sen. Bob Corker, R-Tenn., being the only Republican to vote against the bill. No Democrats voted in favor of the bill.

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Transferee Liability for Unpaid Corporate Taxes of Minority Shareholders

Ronald Marini, Tax Advisor

The Eleventh Circuit affirmed the Tax Court’s determination that petitioner was liable as a transferee under 26 U.S.C. 6901 for his former employer’s unpaid taxes, in Kardash v. Commissioner of IRS, US Court of Appeals for the Eleventh Circuit, Docket: 16-14254.
The Tax Court had previously found two minority shareholders liable to return several million of dividends they received from a corporation when the corporation failed to pay federal income taxes at the direction of majority shareholders, which majority shareholders also drove the company into insolvency by siphoning off corporate funds.

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More Then 31,000 US Taxpayers Exposed in Paradise Papers

Ronald Marini, Tax Advisor

We had posted on October 30, 2017 ‘Another Offshore Law Firm Gets Hacked’ where we discussed that Appleby, an offshore law firm/corporate agent’s recent data breach is yet another example of how the IRS can discover your unreported foreign account and how the super-rich clients of offshore law firm Appleby are bracing themselves for the exposure of their financial secrets, after the firm admitted data had been stolen in a cyber attack last year.

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OECD Report Finds That Tax Haven Islands Are Now Sharing Information

Ronald Marini, Tax Advisor

The Cayman Islands, Bermuda and Mauritius, three of the world’s most famous tax havens, are among the countries deemed “compliant” or “largely compliant” with international standards for tax information exchange, according to a series of reports released Monday by the Organization for Economic Cooperation and Development.

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House Passes Tax Bill With Deep Cuts For Businesses & Territorial Tax for Multinationals

Ronald Marini, Tax Advisor

Last week, House Republicans succeeded in passing wide-reaching tax legislation, overcoming Democrats’ criticisms that it would significantly lower taxes for corporations and the wealthy while short-changing middle-income earners.

The Tax Cuts and Jobs Act, or H.R. 1, was approved by a vote of 227-205 just two weeks after it was introduced. The legislation would have a significant impact on a wide range of industries including technology, energy, pharmaceuticals and real estate, but lawmakers must first iron out differences between the House bill and a companion version under consideration in the Senate.
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Senator Bernie Sanders Call For Senate Investigation of the Offshore Paradise Papers Leak

Ronald Marini, Tax Advisor

Senator Bernie Sanders (I-VT) called for the U.S. Senate to investigate offshore tax evasion following the revelations of the Paradise Papers, adding to the growing voices in Congress who have called for government to take action to address the investigation’s findings.

In a letter to Senate Budget Committee chair Mike Enzi (R-WY), Sanders called on the budget committee to launch a bipartisan investigation to determine how much the use of offshore havens has contributed to the U.S. national debt.

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Americans Who Have Renounced Their Citizenship Heading for Record Year

Ronald Marini, Tax Advisor

As many as 1,400 Americans have renounced their citizenship in the third quarter of 2017, according to US Treasury Department data. The trend suggests the total for 2017 will be more than 6,800, which is 26% above the 2016 total and 56% higher than 2015.

Americans are on pace to renounce their citizenship in record numbers in 2017, according to the latest quarterly report from the Treasury Department.

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Offshore Law Firm’s Data Stolen In Cyber Attack, Denies Wrongdoing

Ronald Marini, Tax Advisor

On September 5, 2017, ‘How Will the IRS Know About My Foreign Account?’ was published. In that blog post, we discussed how taxpayers who have financial assets outside the United States often ask the question:

“How will they (IRS) know about my Foreign Account?”

Many ask this when they are considering how (or whether) to come forward and inform the IRS about their previously undisclosed foreign financial accounts.

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What Happened to the IRS OVDP Website?

Ronald Marini, Tax Advisor

Where you represent as many taxpayers as we do in relation to cleaning up their previously undeclared offshore investments and bank accounts, your are on the IRS’ website daily to review the current elements required by the IRS to qualify for an OVDP (Offshore Voluntary Disclosure Program) filing or an OVDP streamline filing.

You can imagine my surprise when my desktop link to each relevant IRS OVDP page, that I’ve been using for the last 8 years no longer worked.

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TIGTA Says That Improvements Are Needed in the IRS’ Estate and Gift Tax Return Examination Process

Ronald Marini, Tax Advisor

The Internal Revenue Service (IRS) needs to make improvements in the classification, prioritization, and inventory assignment processes for the Estate and Gift Tax Return Examination Program, according to an audit report that the Treasury Inspector General for Tax Administration (TIGTA) issued today.

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