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Monthly Archives: April 2016



Divorced Woman Not Only Gets Her Deceased Ex-Spouse’s Cake … She Gets to Eat It All Without (Estate Tax) Apportionment preview image

Divorced Woman Not Only Gets Her Deceased Ex-Spouse’s Cake … She Gets to Eat It All Without (Estate Tax) Apportionment

Have a US Estate Tax Problem?


Estate Tax Problems Require
an Experienced Estate Tax Attorney
Contact the Tax Lawyers at
Marini & Associates, P.A.
 for a FREE Tax Consultation Contact US at
or Toll Free at 888-8TaxAid (888 882-9243).
Robert S. Blumenfeld  - 
 Estate Tax Counsel

Mr. Blumenfeld concentrates his practice in the areas of International Tax and Estate Planning, Probate Law, and Representation of Resident and Non-Resident Aliens before the IRS.

Prior to joining Marini & Associates, P.A., he spent 32 years as the Senior Attorney with the Internal Revenue Service (IRS), Office of Deputy Commissioner, International.

While with the IRS, he examined approximately 2,000 Estate Tax Returns and litigated various international and tax issues associated with these returns.As a result of his experience, he has extensive knowledge of the issues associated with and the preparation of U.S. Estate Tax Returns for Resident and Non-Resident Aliens, Gift Tax Returns, Form 706QDT and Qualified Domestic Trusts.


Read more at: Tax Times blog

Mossack Fonseca Law Firm Leak & Attorney-Client Privilege

We previously posted DoJ Launches CriminalInvestigation of Hundreds of US Taxpayers Named in Panama PapersLeak! where we discussed that the offshore planning world was set on fire with the news that 11 million documents were leaked from the Panamanian law firm Mossack Fonseca. 

They allegedly show how Mossack Fonseca has helped clients launder money, dodge sanctions and evade tax and now The Guardian reports that U.S. Attorney Preet Bharara has “led several crusades against criminal wrongdoing in the financial sector, is already investigating several of the more than 200 US citizens named in the papers.”

Current and former clients of the law firm subject to the leak now face the potential exposure of their confidential documents and conversations spanning nearly 40 years. Whenever confidential attorney files are leaked, innocent clients, as well as those who may have been seeking to cover up wrongdoing, face the potential of their personal information and confidential files being reviewed by reporters, members of the public and government investigators.
Even when only a subset of the stolen documents are publicized, the DOJ can often obtain additional, nonpublic material through grand jury subpoenas served on the entities or individuals that now possess the stolen files or through mutual legal assistance treaties to foreign authorities.
This raises the question of whether U.S. government investigators are able to make use of these "Privileged Materials" that appear to have been hacked from Mossack Fonseca, an overseas law firm?

Law 360 discusses Attorney-Client Privilege And A Law Firm Leak including whether the 4th amendment and/or privilege applies to these hacked materials. 
Individuals with Potential Exposure Should Consult with U.S. and Local Counsel and Consider Their Legal Options Now!
Any arguments to preserve privilege should be presented as promptly as reasonably possible to minimize the potential for a judicial finding of waiver of privilege. It may take months or even years for the full implications of such leaks to be clear, but for those who anticipate potential legal exposure, the time for them to assess their legal options is now.
All U.S. Taxpayers with
"Unreported Income" or "Money"
in Offshore Accounts
Need To Come Clean NOW before
Their Illegal Activity is Identified! 
 Want to Know which OVDP Program
is Right for You?

Contact the Tax Lawyers at 
Marini& Associates, P.A.  
for a FREE Tax Consultation
Toll Free at 888-8TaxAid (888) 882-9243




Read more at: Tax Times blog

The IRS Issues New Version of Form W-8 BEN-E – Making It Even More Complex

On December 17, 2014 we posted How to Complete Form W-8 BEN E & and W-8IMY? where we discussed how to fill out the various Form W–8's, which now has increased to 8 pages in some cases.

This post provided foreign entities a set of step-by-step instructions to complete the new Forms W-8BEN-E and W-8IMY, as well as a general overview of the obligations imposed on foreign financial institutions under the new chapter 4 FATCA regime including:

  1. Determine which form is appropriate for the foreign recipient to complete
  2. Determine whether the foreign entity is a foreign financial institution (FFI) or a non-financial foreign entity (NFFE)
  3. A foreign entity that meets the definition of a foreign financial institution (FFI) should identify whether an Intergovernmental Agreement (IGA) applies, as well as its requirements under the applicable IGA. and
  4. Any other foreign entity that is not an FFI should determine its specific Chapter 4 non-financial foreign entity (NFFE) status and document that NFFE status on Form W-8BEN-E or W-8IMY.


Now the IRS has issued new versions of Form W-8BEN-E, Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting, and the instructions to that form. The revised form reflects changes made in regulations and other pronouncements. that were issued since the publication of the previous version of the form, as well as changes to more effectively enforce already-existing withholding and reporting rules.

The updates contain several changes to the form itself, some changed instructions, and many instances of added detail to existing instructions. Included among the form changes are:

  1. New chapter 4 status box for accounts that are not financial accounts.
  2. A new checkbox has been added to the chapter 4 statuses in Part I, line 5, for payments made to payees for accounts they hold that are not financial accounts.
  3. Increased information required regarding LOBs for beneficial owners making treaty claims.
  4. Reporting by sponsored FFIs.
  5. Form W-8BEN-E, Part IV, which previously had been entitled “Sponsored FFI That Has Not Obtained a GIIN” is now entitled “Sponsored FFI.” IRS is now requiring disclosures by sponsored FFIs, regardless of whether the FFI has obtained a GIIN and, 
  6. A new line has been added that requests the GIIN of the sponsoring entity and
  7. Increased compliance requirements for nonreporting IGA FFIs.

Have A Tax Problem?

Contact the Tax Lawyers at 
Marini & Associates, P.A.
for a FREE Tax Consultation
at: www.TaxAid.us or www.TaxLaw.ms or
Toll Free at 888-8TaxAid (888 882-9243).


Read more at: Tax Times blog

Over 20 Countries Join UK-led Pilot for Automatic Data Sharing!


Chancellor of the Exchequer, George Osborne hailed the international expansion of a UK-led deal to automatically share information on the ultimate owners of companies as over 20 jurisdictions, including British crown dependencies, overseas territories and EU member states sign up.

Gibraltar, Isle of Man and Montserrat are amongst those joining the pilot initiated by the UK and launched with Germany, France, Italy and Spain at the G20 last week. As such their tax and law enforcement agencies will now exchange data on company beneficial ownership registers and new registers of trusts enabling more effective investigation of financial wrongdoing and tax-dodging.

The Chancellor of the Exchequer, George Osborne said: Only a week after Britain launched this initiative with some of our closest European partners, it’s gaining the international support that will be vital to make it truly effective.

I welcome the early commitment made by Gibraltar, Isle of Man, Montserrat and Anguilla to participate and call on all of the remaining overseas territories and crown dependencies to do likewise.

It should be clear to all countries and tax jurisdictions that the world is moving firmly in the direction of greater tax transparency and the UK will continue to push for an internationally agreed blacklist for those that refuse to do the right thing.

The pilot will begin to explore the best way for countries to share this information, with a view to developing a truly global common standard in a two-step process leading to the interlinking of national registries.

To date the following countries have agree to Automatic Data Sharing:

  1. UK, 
  2. Germany,
  3. France,
  4. Italy 
  5. Spain  
  6. the Netherlands,
  7. Romania,
  8. Sweden,
  9. Finland,
  10. Slovakia,
  11. Latvia,
  12. Croatia,
  13. Belgium,
  14. Ireland,
  15. Slovenia ,
  16. Denmark,
  17. Malta,
  18. Lithuania,
  19. Cyprus,
  20. Bulgaria,
  21. Portugal,
  22. Estonia,
  23. Greece and
  24. Czech Republic.

Have "Unreported" Offshore Income?
 Want to Know which OVDP Program
is Right for You?

Contact the Tax Lawyers at 
Marini& Associates, P.A.  
for a FREE Tax Consultationat: www.TaxAid.us or www.TaxLaw.ms or

Toll Free at 888-8TaxAid (888) 882-9243



HM Treasury

Read more at: Tax Times blog