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Marini & Associates, PA is a law firm based in Miami, Florida whose focus is the practice of TAX LAW and related fields, with an emphasis on Zealously Representing and Defending Taxpayers before the IRS and various State Taxing Agencies.

International Tax Planning

US tax law is notoriously complex and ever-changing. The firm’s attorneys have over 100 years of combined experience in advising on laws, regulations, practices and procedures that impact clients and their businesses.

Whether the concern is US Federal (IRS) or Multi-State tax issues for a domestic or a multinational business entity or planning for a foreign national immigrating to the US (Inbound) or planning for a US taxpayer emigrating from the US as an Expatriate (outbound); Marini & Associates, PA is available to provide proactive advice and tax planning.

Marini & Associates, PA is internationally recognized as a leader in providing tax counsel and legal representation to clients throughout the United States and around the world.

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 US taxpayers who maintain unreported foreign bank accounts. The IRS’s and DOJ’s public campaign to identify US taxpayers with accounts in UBS and other foreign banks has been extensively chronicled by the media and now with the Foreign Account Tax Compliance Act (FATCA) requiring Foreign Financial Institutions (FFI) and certain other non-financial foreign entities to report on the foreign assets held by their U.S. account holders, there is no confidentiality or anonymity for US taxpayers anywhere in the world.

The IRS has also announced that it will focus its efforts on increasing audits of US persons and businesses that make payments to foreign individuals and businesses to ensure the US taxpayers are properly reporting and withholding taxes from those payments.

The IRS also plans to increase audits and investigations of US 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.

Marini & Associates, PA, specializes in representing the following taxpayers with international tax issues:

  • US citizens living and working abroad
  • US citizens with foreign-sourced income
  • US taxpayers with international trusts
  • Non-US taxpayers with US-sourced income
  • US businesses with operations in other countries
  • International businesses with US tax reporting requirements and tax liabilities
  • US and non-US entertainers with worldwide income
  • Expatriates
  • US citizens and residents with undeclared income from offshore bank accounts and other offshore foreign investments.


Marini & Associates, PA’s experienced tax litigators, many of whom are former IRS Tax Attorneys:

  • Know the various Tax Laws
  • Are Seasoned Tax Litigators
  • Are Skilled Advocates and
  • Have a Record of Creativity & Achievement


Contact us for a Free Consultation!


Our Philosophy


We are a Results Oriented law firm that provides Experienced Advice and Tenacious Representation in all of the matters, which we are entrusted with by clients.

Our Philosophy in Planning, is to provide Experienced Solutions for our client’s problems and to structure transactions in order to Avoid or Minimize Future Problems.

Our Philosophy in Tax & Criminal Tax Representation/Litigation, is to provide Experienced Advice and Tenacious Representation, in order to represent our clients to the Full Extent that the Law Allows!

We also believe that Our Clients are our Best Referral Source. Therefore, the firm always endeavors to provide the Maximum Client Satisfaction in its International Tax Planning and in its Defense of Taxpayers during Tax Controversies & Tax Litigation!

If you have been contacted by the IRS or a State/Local Taxing Authority, regarding you or your business' tax liability of, contact Marini & Associates, PA immediately for assistance in representing and defending you from Governmental Agencies actions!

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(888) 882-9243