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Recent Posts by Ronald Marini

A Federal Tax Case Brought in Virgin Islands May Be Transferred

The District Court of the Virgin Islands has “exclusive jurisdiction” over Virgin Island tax cases only vis-a-vis Virgin Island local courts and therefore it could transfer a case to another federal district court, the U.S. Court of Appeals for the Third Circuit held April 12 (Birdman v. Office of the Governor,3rd Cir., No. 10-4189, 4/12/12).…
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IRS Can Reclassify S Corp Distributions as Wages

IRS Knows the Game The IRS is aware of the strategy of using modest S corporation salaries to reduce federal employment taxes for shareholder-employees. The tax-saving advantage is lost if the government successfully asserts that S corporation cash distributions are actually disguised salary payments. Then, the corporation can be hit with back employment taxes, interest,…
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Swiss Court Blocks US Request for Bank Data Under OLD Treaty

Swiss court ruled Switzerland may not hand over the bank details of a Credit Suisse client to U.S. tax authorities, in a potential setback to solving a dispute between the two countries. In a ruling published on Wednesday that cannot be appealed, Switzerland's Federal Administrative Court said the tax office was not allowed to hand…
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IRS & TRAC Disagree on Effectiveness of LB&I's Global High Wealth Group

The audit pace for the Global High Wealth group has picked up in the last year, but remains below target, according to the Transactional Records Access Clearinghouse. As of February 2012, the group has completed 36 audits since its 2009 unveiling, 33 percent of which were “no change audits,” according to new data compiled by…
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