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Recent Posts by Ronald Marini

Tax Fraud Against Preparers Affirmed by the Fifth Circuit

The convictions of a couple that committed tax fraud were affirmed by the Fifth Circuit Court of Appeals. The husband and wife were the owners and operators of a firm that prepared personal income tax returns in Texas. A husband and wife were indicted for offenses arising out of their business of preparing federal income…
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Ecuador Declares “US LLCs” as a Preferential Tax Regime – Tax Haven!

                   Preferential tax regimes are jurisdictions where income is subject to tax at a rate 60% lower than in Ecuador (Ecuador current corporate income tax is 23%). US LLCs have been declared to be a preferential tax regime if owned by US non resident aliens and if income is not subject to federal income tax…
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U.S./U.K. Treaty Does Not Override Code Requirements for Tax-Deferred Rollover

Office of Chief Counsel Internal Revenue Service Memorandum Number: AM2008-009 Release Date: 8/29/2008 CC:INTL:B01:QPHuynh PRENO-136253-08 UILC: 9114.03-42 date : August 21, 2008 to : Michael Julianelle Director, Employee Plans (Tax Exempt and Governmental Entities) from : Associate Chief Counsel (International) subject : UK Pension Rollovers This memorandum addresses the possible application of Article 18 (Pension…
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Jail & Big Fines for Undeclared Swiss Accounts!

Two former clients of UBS AG were sentenced on Monday to a year and a day in prison, matching what records show as the longest prison term ordered so far in a sprawling investigation of offshore tax avoidance involving the Swiss banking giant. Sean and Nadia Roberts of Tehachapi, California, were also ordered to pay…
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