The Congressional Research Service has issued the Congressional Research Service-Issues in International Corporate Taxation: The 2017 Revision (P.L. 115-97) report that looks at how changes made in 2017 by the Tax Cuts and Jobs Act (TCJA, PL 115-97) to the international corporate tax rules addressed concerns under prior tax law and what problems, issues, and legal uncertainties arose…
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About: Ronald Marini
Recent Posts by Ronald Marini
Streamline Offshore Submission Turned Criminal!
According to DoJ, a former CPA Indicted for Failing to Report Foreign Bank Accounts and Filing False Documents with the IRS A federal grand jury returned a superseding indictment charging Brian Booker, a former resident of Fort Lauderdale, Florida, whose business specialized in international trade, with failing to file Reports of Foreign Bank and Financial…
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IRS Warns of New IRS Impersonation Email Scam
The IRS and its Security Summit partners warned tax professionals this week about a new IRS impersonation scam campaign spreading nationally on email. The new scam illustrates the growing sophistication of cybercriminal organizations. The scam now relies on dozens of compromised websites and web addresses that pose as IRS.gov, making it a challenge to…
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A Taxpayer's Limited Education Not Sufficient to Prove Reasonable Cause for Failure to File FBAR
A district court has held in Ott, DC MI 8/7/2019, that the failure-to-file FBAR penalty applied to a taxpayer because she failed to establish reasonable cause for her failure to file. Pursuant to 31 USC § 5314(a), every U.S. person that has a financial interest in, or signature or other authority over, a financial account, or accounts,…
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