According to Law360, the Internal Revenue Service isn't planning to issue additional guidance on the 2017 tax overhaul's deemed repatriation despite a recent announcement that the agency was considering relief for some companies in this area, a top official said January 31, 2020. The agency learned of "few sympathetic cases" in which companies were excessively taxed under…Read more
J5 Undertake Unprecedented Multi-Country Day of Action To Tackle International Tax Evasion
The IRS announced in IR-2020-18 that the J5 conducted a globally coordinated day of action to put a stop to the suspected facilitation of offshore tax evasion has been undertaken this week across the United Kingdom (UK), United States (US), Canada, Australia and the Netherlands. The action occurred as part of a series of investigations in multiple…Read more
Postmark Rule Did Not Apply to Late-Filed Tax Return Requesting a Refund
A district court has held that the postmark rule did not apply to a late-filed tax return that sought a refund of taxes paid. But the court noted that this is an issue of first impression for the 7th Circuit Court of Appeals which might have a different view. A tax return is generally deemed…Read more
Former Large Business & International Senior Counsel for the Office of Chief Counsel, IRS, Joins Marini & Associates, PA.
Marini & Associates, PA is pleased to announce that Sergio Garcia-Pages, Esq., former Senior Counsel for the LB&I Division of the Office of the Chief Counsel, IRS, South Florida, has become "Of Counsel" to our firm. Mr. Garcia-Pages has in-depth knowledge of the IRS and significant U.S. Tax Court experience. He is available to collaborate with…Read more