AICPA - Using the First-Time Penalty Abatement Waiver aicpa.org This article explores the IRS first-time penalty abatement waiver and explains how to help clients remove certain penalties using it. Need Help Getting a Penalty Waved? Contact the Tax Lawyers at Marini & Associates, P.A. for a FREE Tax Consultation Contact US at www.TaxAid.us or www.TaxLaw.ms…
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Surveillance Policies Raise Questions About the Viability of the Attorney Client Privilege?
According to the ABA Journal - Press reports earlier this year indicating that communications between at least one U.S. law firm and a foreign government had been monitored by the Australian equivalent of the U.S. National Security Agency triggered a series of diplomatic exchanges between the ABA and the NSA, focusing on the extent to which…
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Only 13% of US Source Payments are Subject to US Withholding Tax!
The IRS has issued 2 tabular presentations of data for Tax Year 2012 from Form 1042-S, Foreign Person's U.S. Source Income Subject to Withholding. The table for 2012 shows that: Only 13.10% of all US source payments are subject to US withholding tax and Of this 13.10%, which is subject to US withholding tax,…
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Treasury to Amend the PFIC Regulations For US Persons With stock of a PFIC
The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) will amend the regulations under section 1298(f) of the Internal Revenue Code (Code) to provide guidance concerning United States persons (U.S. persons) that hold stock of a Passive Foreign Investment Company (PFIC).Notice 2014-51 SECTION 1. PURPOSE This notice announces that the Department…
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