In PLR 201228013, the IRS considered whether an individual who incurred net operating losses (NOLs) while a resident alien could use the NOLs after he became a nonresident alien. The IRS ruled that he could to the extent the NOLs were allocable and/or apportionable to gross income effectively connected with a U.S. trade or business…
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About: Ronald Marini
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Switzerland Will Allow Grouped Client Disclosure Requests begining in January 2013
The Swiss parliament has agreed that foreign tax authorities will be able to make grouped requests for administrative assistance, specifying suspected tax avoiders by behaviour patterns rather than by name. Unless challenged by foreign clients, the law will come into effect in January 2013. Parliament has approved grouped requests for administrative assistance on tax matters…
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United Kingdom Signed Bilateral FATCA Agreement
Page Content WASHINGTON – The U.S. Department of the Treasury announced today that it has signed a bilateral agreement with the United Kingdom to implement the information reporting and withholding tax provisions commonly known as the Foreign Account Tax Compliance Act (FATCA). Enacted by Congress in 2010, these provisions target non-compliance by U.S.…
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FORMER US AIRWAYS PILOT SENTENCED IN NORTH CAROLINA TO 10 YEARS IN PRISON FOR TAX FRAUD
<!-- -->WASHINGTON – Charles A. Davis, 63, formerly of Mooresville, N.C. was sentenced today in U.S. District Court to 120 Months in Prison for committing tax fraud, the Justice Department and Internal Revenue Service (IRS) announced. U.S. Judge Richard L. Voorhees in the Western District of North Carolina also ordered Davis to serve 12 Months…
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