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Recent Posts by Ronald Marini

New FAQs for Offshore Voluntary Disclosure Program

The IRS said Tuesday that it has collected more than $5 billion in its offshore voluntary disclosure programs (IR-2012-64), the third of which was announced in January this year. At the same time, it also released 55 questions and answers updated for the 2012 program. This program handles penalties the same way the 2011 program…
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Tax amnesty offered to Americans in Canada

The U.S. Internal Revenue Service said it will waive potentially massive penalties for certain “low compliance risk” tax payers who opt to come clean. Shulman announced the IRS will provide a new option to help some U.S. citizens and others residing abroad who haven’t been filing tax returns and provide them a chance to catch…
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Fiduciaries Held Liable For Estate & Gift Tax under Federal Priority Statute

Fiduciaries (trustees, executors, personal representatives) normally are not personally liable for the obligations of the trusts and estates they administer. As mentioned here previously, a major exception to this is the federal priority statute (a/k/a the federal claims statute) under 31 USC §3713(b)/Code § 6901(a)(1)(B). This little gem can create personal liability for a fiduciary…
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Inter-agency cooperation against tax crimes and other financial crimes is the future.

A report by Organisation for Economic Co-operation and Development (OECD) has concluded that International co-operation is essential in the fight against tax and other financial crimes. This report which, was release on June 14, 2012, aims at improving the understanding and use of international co-operation mechanisms. After describing the different agencies involved in the fight…
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