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Recent Posts by Ronald Marini

IRS Targets Israeli Banks and Their US Client

On June 14, the Department of Justice unsealed an indictment against three American tax preparers for helping clients avoid taxes by moving money to Israel.The transgressions detailed in the indictment were relatively small. The indictment said the father and son David and Nadav Kalai and their colleague David Almog at a firm called United Revenue…
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Getting ITIN becomes even more difficult for now.

IR-2012-62, June 22, 2012 WASHINGTON — The Internal Revenue Service announced on June 22, 2012, important interim changes to strengthen its procedures for issuing Individual Taxpayer Identification Numbers (ITINs) from now through the end of the year. Designed specifically for tax-administration purposes, ITINs are only issued to people who are not eligible to obtain a…
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Income from Certain Government Bonds not PFIC Income.

Notice 2012-45 This notice provides guidance regarding the treatment of certain government bonds for purposes of determining whether a foreign corporation is a passive foreign investment company (PFIC). Section 1297(a) provides that a PFIC is any foreign corporation if 75 percent or more of its gross income for the taxable year is passive income or…
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