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Recent Posts by Ronald Marini

Foreign Banks in 140 Countries Draw IRS Scrutiny

The U.S. Treasuryannounced the current results of the Tax Amnesty that was offered for 2011 with the extended deadline of September 9, 2011. A total of more than 30,000 individuals have come forward under the amnesty programs for 2009 and 2011. The amount of additional revenue collected just on the 2009 amnesty program exceeded $2,200,000,000.…
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Newly Released Form 8938 – Statement of Specified Foreign Financial Assets

The IRS just released a new DRAFT of Form 8938 and a first DRAFT set of Instructions. This Statement of Specified Foreign Financial Assets needs to be attached to and filed with the taxpayer's tax return (eg Form 1040) in addition to filing the FBAR (TDF 90.22.1) for all tax years starting after March 18, 2010.  Therefore calendar year…
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IRS Chief Counsel Reissues Tax Levy Guidance

The IRS Small Business/Self-Employed Division Sept. 29 reissued interim guidance for issuing a notice of intent to levy/notice of a right to a hearing in a collection field function to a taxpayer. In SBSE-05-0911-081, dated Sept. 26, the memorandum said after issuing Letter 1058 to a taxpayer, 15 extra days must elapse after the 30-day…
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HSBC India Client Indicted by U.S. Over $8.7 Million Account

Sept. 28 (Bloomberg) --  A Wisconsin neurosurgeon was re- indicted by a U.S. grand jury on new charges that he failed to declare an HSBC Holdings Plc account in India valued in 2009 at $8.7 million. Arvind Ahuja was indicted again by a federal grand jury in Milwaukee, where he was initially charged June 28 with…
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