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Recent Posts by Ronald Marini

IRS Continues Extreme Pressure on Swiss Banks for More Information

The US government is piling further pressure on Credit Suisse for the release of more information on its clients. Switzerland's Finance Minister Eveline Widmer-Schlumpf says the US is 'constantly making new demands that we cannot accept', thus delaying resolution of their dispute over the prosecution of 11 Swiss banks. If you have a Credit Suisse…
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Trouble for Offshore Bank Account Owners at Liechtensteinische Landesbank AG (LLB)

According to a spokesman for LLB quoted in the article, changes in Lichtenstein law allow the IRS to make group requests without providing the names of the specific individuals that the IRS is seeking. The spokesman also stated that in the Liechtenstein group request, U.S. authorities are also targeting lawyers, accountants, financial advisers, asset managers…
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No FBAR Penalty Exceptions for Voluntary Disclosure and Plea Bargins

What a difference one court case makes. Gone is the believe that it was almost impossible for the IRS to get the BIG FBAR penalty (of half the value of the offshore bank account for each and every unreported year). United States Court Of Appeals for The Fourth Circuit reversed a district court opinion in…
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House Passes a Blueprint for Tax Reform – Top Rate 25%

The House of Representatives, on August 2, approved H.R. 6169, the Republican-backed “Pathway to Job Creation througha Simpler, Fairer Tax Code Act of 2012.” The bill would provide expedited procedures to enable lawmakers in both the House and Senate to overcome technical hurdles that might cause a “comprehensive tax reform” bill to languish during the…
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