call us toll free:

888-8TAXAID
(888-882-9243)
Monday - Friday from 9:00 am to 5:00 pm

Monthly Archives: November 2014

Big Wahoo!!!

For all of our friends who are concerned that we hereand Marini & Associates, PA are all work and no play, please be advised that we caught this large Wahoo during our recent trip to Bimini.

If you like fishing, don't be shy to join us on our next adventure!

Very truly yours,   

Marini & Associates, P.A.

By  Ronald A. Marini
     Ronald A. Marini, Esquire

Read more at: Tax Times blog

Luxemburg Leaks’ causes ‘Tax storm’ of government, media response

Newspaper front pages.Public officials across the globe reacted with swift condemnation and calls for reform following ICIJ’s investigation into secret tax deals between Luxembourg and hundreds of international corporations.

The New York Times said the revelations have sparked a “rising furor” in Europe. Reuters called the reaction a “tax storm.” Response has been especially intense in Brussels, where the European Commission has been seeking to eliminate tax havens within the European Union.

Reporting by ICIJ and its partners was based on a leak of 548 private tax rulings – also known as “comfort letters” – negotiated by accounting giant PricewaterhouseCoopers on behalf of more than 340 multinational corporations. The documents provided a road map into how corporations shave billions of dollars in taxes by routing profits through Luxembourg. 

At the center of the “Lux Leaks” controversy is Jean-Claude Juncker, new president of the European Commission. Juncker was Luxembourg’s prime minister at the time many of the country’s tax-avoidance rules were enacted.

To see more about the latest impacts and responses link to ICIJ.

Have Un-Reported Income From an Offshore Bank?

 
Value Your Freedom?
 
Taxpayers who wish to take advantage of the OVDP 
Must Act Quickly!  
Contact the Tax Lawyers at
Marini & Associates, P.A.
for a FREE Tax Consultation Contact US at
or Toll Free at 888-8TaxAid (888 882-9243)

Read more at: Tax Times blog

US Expatriation Continues to Increase At a Record Pace in 2014!

We previously posted US Expatriation Increase At a Record Pace in 2014!  where we discussed that the number of Americans renouncing U.S. citizenship stayed near an all-time high in the first half of the year before rules that make it harder to hide assets from tax authorities came into force (FATCA - Effective Date July 1, 2014). 


Each quarter the U.S. Treasury publishes the names of the Americans who officially expatriated during that period.

People giving up their nationality at U.S. embassies increased to 777 in the third quarter, from 560 in the year-earlier period, according to Federal Register data published yesterday.

Tougher asset-disclosure rules that started July 1 under the Foreign Account Tax Compliance Act, or FATCA, prompted more of the estimated 6 million Americans living overseas to give up their passports. The appeal of U.S. citizenship for expatriates faded further as more than 100 Swiss banks began to turn over data on American clients to avoid prosecution for helping tax evaders.

The U.S., the only Organization for Economic Cooperation and Development nation that taxes citizens wherever they reside, stepped up the search for tax dodgers after UBS AG paid a $780 million penalty in 2009 and handed over data on about 4,700 accounts. Shunned by Swiss and German banks and with FATCA starting, more than 9,000 Americans living overseas gave up their passports over the past five years.

FATCA requires U.S. financial institutions to impose a 30 percent withholding tax on payments made to foreign banks that don’t agree to identify and provide information on U.S. account holders. It allows the U.S. to scoop up data from more than 77,000 institutions and 80 governments about its citizens’ overseas financial activities.

In establishing the 2010 FATCA law, Congress and President Barack Obama in effect threatened to cut off banks and other companies from easy access to the U.S. market if they didn’t pass along such information. It was projected to generate $8.7 billion over 10 years, according to the congressional Joint Committee on Taxation.

So far, 2,353 Americans have renounced their citizenship 
this year, close to the all-time high of 2,369 
in the first nine months of 2013.

If this current trend continues,  it would result in  3,154 people expatriating into 2014, which would be a 105%  increase over the 2,999 people who expatriated in 2013. The 2013 amount of 2,999 represented a 221% increase over the 932 total in 2012 and “shatters” the previous record of 1,781 set in 2011.



"Should I Stay or Should I Go"?

 
Need Advise on Expatriation ...
 

Contact the Tax Lawyers of
Marini & Associates, P.A.

For a FREE Tax Consultation at:

Toll Free at 888-8TaxAid (888 882-9243)
Source:


US Treasury
Bloomberg

Read more at: Tax Times blog

DoJ Indicts Another Swiss Banker on Heels of 2 Recent Acquittals.

On November 3, 2014, we posted Ex-UBS Exec & Ex-Mizrahi Banker Found Not Guilty In Tax Evasion Trials!where we discussed that jurors in federal court in Fort Lauderdale, Florida, found former UBS AG executive Raoul Weil not guilty of conspiracy to defraud the United States for his alleged role in helping nearly 20,000 U.S. clients hide $20 billion in assets from the Internal Revenue Service.

The decision came as a significant blow to federal prosecutors, who had focused their efforts on convicting Weil, formerly the third-ranked officer at the Swiss banking giant as the head of its wealth management and business banking division and the most senior individual they targeted.
This came on the heels of Friday's (October 31, 2014) acquittal of a retired senior vice president at Israeli-based Mizrahi Tefahot Bank Ltd. in Los Angeles federal court on charges he helped U.S. customers conceal their assets from the Internal Revenue Service. 
Shokrollah Baravarian, 82,was charged with conspiring to defraud the U.S. and helping Mizrahi clients prepare false tax returns. Prosecutors claimed Baravarian helped clients who opened accounts in Israel, didn’t declare them to the IRS and accessed money through loans from the Los Angeles branch.

These acquittals represent a substantial setback 
to the seven-year U.S. campaign to curtail offshore tax evasion. 
We then posed the question of whether these 2 recent losses in foreign banker/promoter cases may have a chilling effect on the DoJ's desire to obtain prison terms for bankers/promoters currently under investigation and could possibly cause the DoJ to also rethink prison terms for U.S. Taxpayers with undisclosed offshore accounts. 
Now we know the answer to this question, which is that these 2 losses have not caused the DoJ to change it desire to obtain prison terms for bankers/promoters.

According to Forbes, another high level Swiss banker has been charged with conspiring to evade U.S. taxes. The latest indictment is of Martin Dunki, formerly Senior VP at Swiss private bank Rahn & Bodmer. He lives in Switzerland and has not been arrested, but has been charged with one count of conspiracy to defraud the IRS. It carries a maximum sentence of five years in prison.

This is in accord with Robert Panoff's quote in our November 12, 2014 post The Weil Not Guilty Verdict - Road Map For Future Criminal Defense Strategies?  where he indicated that the pressure is still on foreign bankers who have assisted American taxpayers in hiding money through offshore shell companies and secret accounts.

"The acquittal of Raoul Weil is the loss of one battle in what has been an enduring, lengthy and highly successful war on U.S. tax evasion involving the use of foreign bank accounts and those who aid and abet their conduct." Panoff said.

______________________________

"Those who think that this result will cause 
the Justice Department and the IRS to retreat 
in their ongoing efforts Should Rethink Their Position."
______________________________

Today, almost no offshore account or trust is safe. Already many countries are implementing broad disclosure policies, even Russia and China.For Americans who fail to step forward, the IRS and Department of Justice warn of their vast resources. The IRS and Justice Department may not be scorching the earth, but they aren’t far off.

Offshore accounts and the income and penalties associated with them have accounted for billions of dollars flowing to the IRS over the last 5 years. And it isn’t over yet!!!

Have Un-Reported Income From an Offshore Bank?

 
Value Your Freedom?
 

 Taxpayers who wish to take advantage of the OVDP 

Must Act Quickly!  



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

Read more at: Tax Times blog