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Yearly Archives: 2012

An Interview with Jon McBride and the Hidden Facts behind his FBAR Judgment!

Anthony Parent's post FBAR Defendant Jon McBride warns others to come clean regarding his interview with Jon McBride about the facts surrounding his FBAR penalty judgment is worth reading.

What he did could have happened to anybody. Victimized in a ponzi-scheme, he claims the IRS taxed him on income he never received. And then because he represented himself at audit, that process did not go so well.

Even though McBride had no control to distribute money from foreign accounts, the court held that his "tacit control" was tantamount to "actual control," thus the FBAR penalties were appropriate.

Jon"s advice to anyone who hasn't come clean: OVDI is a "no-brainer," he says.

If you have Un Reported Income from Foreign Bank Accounts, contact the Tax Lawyers at Marini& Associates, P.A. for a FREETax Consultation at or or Toll Free at 888-8TaxAid (888 882-9243).

Read more at: Tax Times blog

IRS SFR Unit Not Accepting International Case Closures

In SBSE-05-1112-086, Scott Reisher, Director, Collection Policy, instructed the ASFR unit not to currently accept international standalone case closures. This memorandum indicates that all cases meeting Automatic Substitute For Return criteria (ASFR), will be referred to IRS's campus in Memphis, Tenn.
The ASFR Unit is currently not accepting international standalone del ret closures under IRM All Cases meeting ASFR criteria under IRM will be referred to the Memphis Campus.

In the interim, international revenue officers should follow the closing instructions under IRM and select the "Exam Referral" option listed below:

1. Select "Exam Referral" on ICS to close the ICS Del Ret module(s)

2. Document the total IRP amount(s) for each tax year in the ICS history

3. Document the reason for not using ASFR referral in the ICS history

"ASFR International block"

4. Prepare a secure email "e-referral" to the Memphis campus using the email address


5. Use "HINF-SFR" as the subject of your email

6. Include the following in your email message

Subject: HINF-SFR

Taxpayer’s TIN: NNNNNNNNN (no dashes)

Have and International Collection Problem?

Contact the Tax Lawyers at Marini & Associates, P.A. for a FREETax Consultation at or or Toll Free at 888-8TaxAid (888 882-9243).


Read more at: Tax Times blog

Amazon's Billion Dollar Tax Dodge.

LUXEMBOURG, Dec 6 (Reuters) - In 2005, Amazon rented a historic five-story building in Luxembourg's Grund quarter, right at the bottom of a steep rock-walled valley below the old town. By setting up in Luxembourg, and channeling sales through its units there, the world's biggest online retailer could minimize corporate taxes.

Amazon's Luxembourg arrangements have deprived European governments of hundreds of millions of dollars in tax, as reported in European newspapers. But a Reuters examination of accounts filed by 25 Amazon units in six countries shows how they also allowed the company to avoid paying more tax in the United States, where the company is based.

Amazon revealed last year that the U.S. Internal Revenue Service (IRS) wants $1.5 billion in back taxes. The claim, which Amazon said it would "vigorously contest", is linked to its foreign subsidiaries and payments made between them.

In effect, Amazon used inter-company payments to form a tax shield for the group, behind which it has accumulated $2 billion to help finance its expansion. This special report tells the story of how Amazon set up the shield, and how it works.

The case highlights the way multinationals reduce their taxes by parking intellectual property in tax havens and charging affiliates big fees for using it. Politicians in rich countries are beginning to target such practices, which have been used by other multinationals including Google and Microsoft.

For Amazon's tax-free money-making machine to work, it had to show it had more than a nameplate in Luxembourg.

To benefit from favorable taxation, the Grand Duchy says firms "must ensure that they give adequate substance to their presence in the country in terms of both logistics and staff." At the end of 2005, Amazon had just a dozen staff there. If tax departments around the continent were to recognize the arrangement, Amazon needed a meaningful corporate presence.

In February 2006, it transferred ownership of its UK, German and French businesses to Amazon EU S.a.r.l., and ownership of its UK and French web domains to Amazon Europe Holding Technologies. It also moved some U.S. executives to Luxembourg, hired more locals and began to call Amazon EU its European headquarters.

Filings show that in December 2006, the group relocated its Luxembourg operating units into the rented building on Plaetis Steet, a stone's throw from the English and Irish bars that prompt the city-state's tourist office to describe the Grund and neighboring Clausen as the "Headquarters of Luxembourg's night life."
At home in the United States, though, the Internal Revenue Service seems unconvinced.

Amazon disclosed in April 2011 that the IRS wanted $1.5 billion in unpaid taxes and fines. It has declined to say exactly what transactions the charge relates to but said it was linked to "transfer pricing with our foreign subsidiaries" over a seven-year period from 2005.

"We disagree with the proposed adjustments and intend to vigorously contest them," Amazon said at the time. "If we are not able to resolve these proposed adjustments ... we plan to pursue all available administrative and, if necessary, judicial remedies."
Want To Know If Your Tax Plan Is Actually A Tax Dodge?
Contact the Tax Lawyers at Marini & Associates, P.A. for a FREETax Consultation at or or Toll Free at 888-8TaxAid (888 882-9243).

Read more at: Tax Times blog

Switzerland Agrees to US FATCA Implementation!

Switzerland has agreed to comply with U.S. disclosure rules on offshore accounts controlled by Americans set for 2014, Swiss president Eveline Widmer-Schlumpf said on Tuesday.

"We have initialled the agreement," Widmer-Schlumpf said in parliament in response to questions from lawmakers, without providing further details.

The agreement, which will come up for final government approval in January, would reconcile Swiss secrecy rules with U.S. disclosure demands under the Foreign Account Tax Compliance Act (FATCA) enacted in 2010.

The act requires foreign financial institutions to tell the U.S. Internal Revenue Service about Americans' offshore accounts worth more than $50,000.

Widmer-Schlumpf denied a link between initial agreement on FATCA and separate, ongoing discussions aimed at ending U.S. probes into 11 banks suspected of helping clients dodge U.S. taxes with offshore bank accounts.

Are you a US Person with UNREPORTED INCOME from a Foreign Bank Account???  

Have FATCA Problems???

Contact the Tax Lawyers at Marini & Associates, P.A. for a FREE Tax Consultation at: or or Toll Free at 888-8TaxAid (888 882-9243).



Read more at: Tax Times blog