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Criminal Investigations and Prosecutions

International Tax Litigation

The Internal Revenue Service has committed to renewed efforts to pursue international violations of the tax laws by individuals and businesses. In order to address what it considers to be an area rife with abusive tax avoidance behavior, the IRS is aggressively pursuing international tax violations through use of both civil audits and criminal investigations and prosecutions.

The IRS has announced specific plans to focus on combating international tax fraud and tax evasion by expanding its programs of information sharing and cooperation with nations around the world. The IRS’s most recent efforts in this area have been against U.S. taxpayers who maintain unreported foreign bank accounts. The IRS’s and DOJ’s public campaign to identify U.S. taxpayers with accounts in UBS and other foreign banks has been extensively chronicled by the media.

The IRS has also announced that it will focus its efforts on increasing audits of U.S. persons and businesses that make payments to foreign individuals and businesses to ensure the U.S. taxpayers are properly reporting and withholding taxes from those payments. The IRS also plans to increase audits and investigations of U.S. individual and business taxpayers with foreign sourced income, foreign bank accounts and foreign trusts. To accomplish these goals, the IRS announced it plans to hire as many as 800 new employees to focus solely on international tax compliance issues.

At Marini & Associates PA, we specialize in representing the following taxpayers with international tax issues:

   U.S. citizens living and working abroad

   U.S. citizens with foreign-sourced income

   U.S. taxpayers with international trusts

   Non-U.S. taxpayers with U.S.-sourced income

   U.S. businesses with operations in other countries

   International businesses with U.S. tax reporting requirements and tax liabilities

   U.S. and Non-U.S. entertainers with worldwide income


  U.S. Citizens & Residents with undeclared income from Offshore Bank Accounts & other Offshore Foreign Investments.

If you have been contacted by the IRS regarding international reporting and/or tax liability issues, contact Marini & Associates PA today for assistance representing and defending your international activities.

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