A district court has found that the taxpayers' failure to timely file a Foreign Bank and Financial Accounts Report (FBAR) was willful where, among other things, they stopped employing a bookkeeper or keeping any books after opening a foreign bank account and made several misrepresentations under penalty of perjury when they applied to participate in…
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1st Circ. Ct of Appeals Reverses Santander's $234M Foreign Tax Refund
According to Law360 the First Circuit Court of Appeals overturned an earlier $234 million victory for Santander Holdings USA Inc. after ruling on December 16, 2016 that an internal securities transaction the bank had engaged in lacked economic substance and does not qualify for foreign tax credits. On November 16, 2015 we posted Judge Rules Thant IRS…
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Marini & Associates, P.A. wishes you a Merry Christmas, Happy Hanukkah and a Happy and Prosperous New Year !
Marini & Associates, P.A. wishes you a Merry Christmas, Happy Hanukkah and a Happy and Prosperous New Year ! Tax Litigation Tax Collections & Tax Planning www.TaxLaw.ms ¡Feliz Navidad y Prospero Año Nuevo! Read more at: Tax Times blog
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IRS Removes QI, WP, and WT Questions from the FATCA Online Registration System
Soon, the IRS will launch a new Qualified Intermediary (QI), Withholding Foreign Partnership (WP) and Withholding Foreign Trust (WT) system allowing these entities to manage their information online. The QI, WP and WT related questions will be available in the new system. Additional information on the updates to the FATCA Online Registration System is available…
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