A district court has denied IRS's motion for summary judgment in a case dealing with the Code Sec. 6677 penalty for failure to file Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts. The court concluded that there was a genuine issue of material fact about whether…
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About: Ronald Marini
Recent Posts by Ronald Marini
US Decrypts Swiss Bank Data – Swiss Privacy Regulator Orders Banks to Stop Information Transfer to the US – Swiss Reaction to US Detention of Banker’s Children
Earlier this month, a Swiss bank employee's two children were detained on arrival in the US on a visit to their grandparents, and questioned for several hours about their father's whereabouts. The incident has prompted Switzerland's data protection watchdog to forbid banks to pass any more employee information to the American authorities. Hanspeter Thür has…
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Bond in lieu of Notice of Federal Tax Lien
Office of Chief Counsel Internal Revenue Service memorandum Number: 201231001 Release Date: 8/3/2012 CC:PA:04 :DSkinner GL-105093-12 UILC: 7101.00-00 date : April 13, 2012 to : Michael R. Fiore Associate Area Counsel (Boston, Group 2) (Small Business/Self-Employed) from : Mitchel S. Hyman Senior Technician Reviewer, Branch 3 (Procedure & Administration) subject : Bond in lieu of…
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Credit Suisse & Wegelin Client Pleads Guilty to FBAR Violation.
An 83-year-old Massachusetts man who held Swiss bank accounts at Credit Suisse Group AG (CSGN) and Wegelin & Co. pleaded guilty to hiding $5.7 million from U.S. tax authorities. Jacques Wajsfelner admitted in federal court in Manhattan that he failed to file Foreign Bank and Financial Accounts Reports. He will pay civil penalties of $2.84…
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