Tag Archive for Ronald Marini

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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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

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

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!

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