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About us

ABOUT US

 

WE ARE AN INTERNATIONAL
& TAX LITIGATION LAW FIRM

 

Marini & Associates, PA is a leader in providing Tax Advice and Tax Defense Representation to clients throughout the United States and around the world.

Based in Miami, Florida our focus is the practice of Tax Law, with an emphasis on Zealously Representing & Defending Taxpayers before the IRS and various Other Tax Authorities.

If you have been contacted by the IRS or Other Tax Authority, regarding you or your tax liability, contact Marini & Associates, PA immediately for HELP in representing and defending you from further Governmental Actions!

Our Team of Tax Attorneys have > 100 years of combined experience, are highly effective, solution-oriented tax attorneys, who care about the clients we represent.

We have successfully represented numerous taxpayers before the IRS and we are included in Martindale–Hubbell's Bar Registry of "Preeminent Lawyers" and we are also listed in "Lawyers of Distinction".

 

International Tax Planning

 

US tax law is notoriously complex and ever-changing. The firm’s attorneys have over 100 years of combined experience in advising on laws, regulations, practices and procedures that impact clients and their businesses.

Whether the concern is US Federal (IRS) or Multi-State tax issues for a domestic or a multinational business entity or planning for a foreign national immigrating to the US (Inbound) or planning for a US taxpayer emigrating from the US as an Expatriate (outbound); Marini & Associates, PA is available to provide proactive advice and tax planning.

Our Philosophy in Planning, is to provide Experienced Solutions for our client’s problems and to structure transactions in order to Avoid or Minimize Future Problems.

 

International Tax Litigation

 

The Internal Revenue Service has committed to renewed efforts to pursue international violations of the tax laws by individuals and businesses. In order to address what it considers to be an area rife with abusive tax avoidance behavior, the IRS is aggressively pursuing international tax violations through use of both Civil Audits and Criminal Investigations and Prosecutions.

The IRS has announced specific plans to focus on combating international tax fraud and tax evasion by expanding its programs of information sharing and cooperation with nations around the world. The IRS’s most recent efforts in this area have been against US taxpayers who maintain unreported foreign bank accounts. The IRS’s and DOJ’s public campaign to identify US taxpayers with accounts in UBS and other foreign banks has been extensively chronicled by the media and now with the Foreign Account Tax Compliance Act (FATCA) requiring Foreign Financial Institutions (FFI) and certain other non-financial foreign entities to report on the foreign assets held by their U.S. account holders, there is no confidentiality or anonymity for US taxpayers anywhere in the world.

The IRS has also announced that it will focus its efforts on increasing audits of US persons and businesses that make payments to foreign individuals and businesses to ensure the US taxpayers are properly reporting and withholding taxes from those payments.

The IRS also plans to increase audits and investigations of US individual and business taxpayers with foreign sourced income, foreign bank accounts and foreign trusts. To accomplish these goals, the IRS announced it plans to hire as many as 800 new employees to focus solely on international tax compliance issues.

Marini & Associates, PA, specializes in representing the following taxpayers with international tax issues:

  • US citizens living and working abroad
  • US citizens with foreign-sourced income
  • US taxpayers with international trusts
  • Non-US taxpayers with US-sourced income
  • US businesses with operations in other countries
  • International businesses with US tax reporting requirements and tax liabilities
  • US and non-US entertainers with worldwide income
  • Expatriates
  • US citizens and residents with undeclared income from offshore bank accounts and other offshore foreign investments.

 

IRS Tax Audits, Tax Appeals, Tax Collections & Tax Litigation

 

IRS Audit

Undergoing an IRS audit can be a very stressful time for the taxpayer. IRS tax audits can also place serious financial and emotional burdens on individuals and businesses. These investigations are often stressful, time-consuming and intrusive. When businesses and individuals learn they may be the subject of an IRS investigation, they need to have a dedicated tax lawyer on their side to fully represent and protect their interests

Marini & Associates, P.A.’s audit attorneys, many of whom are former IRS Tax Attorneys, have experience in working and negotiating with the IRS. Once you retain us, you will never have to deal with the IRS; we do it for you!

Marini & Associates, P.A.’s tax attorneys manage the stress of dealing with the IRS for you. They also protect your rights and your interests while aggressively defending your tax reporting positions.

The tax audit attorneys at Marini & Associates, P.A. know the procedural issues, problems and benefits in dealing with the IRS. Our firm is experienced at working with the IRS to resolve audits as efficiently as possible. Your tax defense attorneys at Marini & Associates, P.A. will coordinate with the IRS revenue agents early on in the audit process to establish the audit parameters and we work with the taxpayer to present their materials in the most effective manner. Our knowledge of IRS audit procedures and regulations helps us protect the taxpayer’s rights and prevent abuses by the IRS.

 

IRS Appeals

 

Unfortunately not all tax issues can be resolved at the IRS audit level. In these circumstances, Marini & Associates, P.A.’s skilled tax lawyers will navigate the client through the process of making a successful appeal to the IRS Office of Appeals (“IRS Appeals”).

The IRS Appeals is a neutral body within the IRS that is dedicated to resolving disputes between taxpayers and the IRS without the need for litigation. The attorneys at Marini & Associates, P.A. have experienced great success resolving unfavorable audits utilizing the IRS Appeals process and negotiating offers in compromise (OIC) on behalf of our clients. The OIC program allows a taxpayer to negotiate a settled amount with the IRS that is less than the full amount owed, giving the taxpayer a fresh start.

The attorneys at Marini & Associates, P.A. are committed to achieving the best possible result for each of our clients. Marini & Associates, PA’s experienced tax litigators, many of whom are former IRS Tax Attorneys and one who was an IRS Area Director of Appeals for > 12 years, provides us with a unique appreciation of the procedures and options employed by IRS appeals officers. This expertise allows each of our IRS lawyers to evaluate cases to determine when an appeal is appropriate and to successfully represent clients throughout the IRS appeals process. When necessary, the attorneys at Marini & Associates, P.A are prepared to aggressively litigate unsuccessful appeals cases before the U.S. Tax Court and other federal courts.

 

Tax Litigation

 

Although most tax disputes are resolved through the during IRS audits and appeals procedures, if a favorable outcome cannot be achieved administratively, taxpayers have the right to litigate their cases in the federal court system. The United States Tax Court is the most common forum in which these types of cases are litigated. Cases involving IRS disputes can also be brought before the United States District Court and the United States Court of Federal Claims. Litigating a case in any of these federal courts is a challenging process and a successful result often hinges upon the skills of an experienced federal tax litigator.

Marini & Associates, P.A.’s team of trial lawyers specialize in IRS federal tax litigation. We have > 100 years of combined experience in successfully representing clients during the IRS tax audit, appeals and litigation processes. Our clients include individual taxpayers, corporations, partnerships, trusts, estates, high net worth individuals and other entities in the United States and abroad. Most of the lawyers at our firm worked for the IRS and the U.S. Tax Court before joining Marini & Associates, P.A. This experience gives each of our tax lawyers a strategic advantage when guiding clients through complex federal court procedures.

Marini & Associates, PA’s experienced tax litigators, many of whom are former IRS Tax Attorneys:

  • Know the various Tax Laws
  • Are Seasoned Tax Litigators
  • Are Skilled Advocates and
  • Have a Record of Creativity & Achievement

 

Don’t take on the IRS by yourself!

 

Contact us for a Free Consultation!

 

 

OUR PHILOSOPHY

 

We are a Results Oriented law firm that provides Experienced Advice and Tenacious Representation in all of the matters, which we are entrusted with by clients.

Our Philosophy in Planning, is to provide Experienced Solutions for our client’s problems and to structure transactions in order to Avoid or Minimize Future Problems.

Our Philosophy in Tax & Criminal Tax Representation/Litigation, is to provide Experienced Advice and Tenacious Representation, in order to represent our clients to the Full Extent that the Law Allows!

We also believe that Our Clients are our Best Referral Source. Therefore, the firm always endeavors to provide the Maximum Client Satisfaction in its International Tax Planning and in its Defense of Taxpayers during Tax Controversies & Tax Litigation!

If you have been contacted by the IRS or a State/Local Taxing Authority, regarding you or your business' tax liability of, contact Marini & Associates, PA immediately for assistance in representing and defending you from Governmental Agencies actions!

 
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