The agreement, which Argentine officials said they were pursuing in September, is part of a government crackdown on alleged tax evasion by individuals. Argentina also has implemented a tax amnesty plan to recover an estimated $500 million in assets held abroad.In a December 23, 2016 statement, Treasury Secretary Jacob J. Lew said the U.S. hopes…Read more
Recklessness = Willful Failure To File FBAR For Partial Disclosure in OVDP Filings
A district court has found that the taxpayers' failure to timely file a Foreign Bank and Financial Accounts Report (FBAR) was willful where, among other things, they stopped employing a bookkeeper or keeping any books after opening a foreign bank account and made several misrepresentations under penalty of perjury when they applied to participate in…Read more
1st Circ. Ct of Appeals Reverses Santander's $234M Foreign Tax Refund
According to Law360 the First Circuit Court of Appeals overturned an earlier $234 million victory for Santander Holdings USA Inc. after ruling on December 16, 2016 that an internal securities transaction the bank had engaged in lacked economic substance and does not qualify for foreign tax credits. On November 16, 2015 we posted Judge Rules Thant IRS…Read more
Marini & Associates, P.A. wishes you a Merry Christmas, Happy Hanukkah and a Happy and Prosperous New Year !
Marini & Associates, P.A. wishes you a Merry Christmas, Happy Hanukkah and a Happy and Prosperous New Year ! Tax Litigation Tax Collections & Tax Planning www.TaxLaw.ms ¡Feliz Navidad y Prospero Año Nuevo! Read more at: Tax Times blogRead more