there is a repeal of the ACA and associated taxes. While at this time, it is unclear what a replacement bill may look like.

 

For individuals, expect:  

1. The elimination of the alternative minimum tax,
2. The elimination of the estate and gift taxes
3. An individual tax cut and a collapsing of the current seven tax brackets into three tax brackets as contained in the Ryan blueprint introduced last year. (House GOP. (2016). “A Better Way.” 
4. Reduced capital gains and dividend tax rates

For Corporations: 

1. Lowering the top corporate rate to 30 percent from the current 35 percent, 
2. Capping the top rate on pass-through entities at 25 percent and
3. A permanent reduction in the tax rate for profits from overseas to 8.75 percent for cash and cash-equivalent profits and 3.5 percent on other profits.

Wall Street and corporate America also view President Donald Trump’s bold agenda for a sweeping tax overhaul as largely dead for the year.

Executives, lobbyists and Wall Street analysts increasingly believe the administration, distracted by repeated crises while facing a short and crowded legislative calendar, will be unable to deliver on Trump’s promise to slash corporate and individual tax rates this year and ignite significantly faster economic growth.

“It is just completely unrealistic to think they can get a big tax reform bill done this year,” said Greg Valliere, chief global strategist at Horizon Investments. “They haven’t even agreed whether they are doing tax cuts or tax reform. They haven’t decided if it needs to be paid for or not and I don’t think they appreciate just how big a fight the debt limit is going to be.”

To make matters worse according to Law360,  the GOP Has No Tax Plan B Without a Border Adjustment Tax.

“There’s not a plan B,” Rep. Peter Roskam, R-Ill. said when asked if the House GOP has a backup tax proposal, without border adjustment, in the event the controversial plan proves too toxic to pass.

“2017 is the year,” Roskam said, arguing that if tax reform isn’t passed this year the momentum could be lost. 

 

Need Tax Advice?

 

 

 

Contact the Tax Lawyers at 

Marini& Associates, P.A.  

 

 

for a FREE Tax Consultation

at: www.TaxAid.com or www.OVDPLaw.com or

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

 

 

 

.

The British Virgin Islands’ Government has signed new legislation regarding Beneficial Ownership & Technical Protocol with the UK which will come into force in June 2017, which is hoped to improve the exchange of beneficial ownership information between the UK & BVI law enforcement for taxation rulings.

• Company name.
• Incorporation number.
• Registered Office Address.
• Incorporation date.

Beneficial Owner details will include the following:

• Beneficial Owner name.
• Beneficial Owner date of birth.
• Beneficial Owner Particulars such as passport number.
• Status of Entity (whether active or inactive etc.).
• Date Liquidation commenced & completed (where applicable).
• Reasons as to why any information is incomplete or not provided.

Each agent registered with the system will have their own user profile and secured space to store the required information (as listed above).

Do You Still Have Undeclared Income from

Offshore Banks or BVI Companies?

 

 

 

Want to Know if the OVDP Program is Right for You?

 

Contact the Tax Lawyers at 

Marini& Associates, P.A.  

 

 

for a FREE Tax Consultation

at: www.TaxAid.com or www.OVDPLaw.com or

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

 

 

 

As it relates to potential tax changes as a result of the Trump administration, we posted:

1. Border Tariff or Border Adjustment Tax or US VAT?
2. Trump Presidency Could Be Death Knell For Estate Taxes!
3. President-Elect Donald Trump Is Less Than Ideal for Tax Advisers?

First, they are assuming that there is a repeal of the ACA and associated taxes and that there is also a general framework for a replacement bill. At this time, it is unclear what a replacement bill may look like. However, for the purposes of our analysis, we assume that the ACA is replaced with a similar-sized plan resulting in little if any additional changes in the size of the federal budget deficit over their forecast horizon, the end of 2018. 

They are also assuming that corporate tax cuts are enacted in the following way: 

• lowering the top corporate rate to 30 percent from the current 35 percent and
• capping the top rate on pass-through entities at 25 percent.  

Wells Fargo also expects a permanent reduction in the tax rate for profits from overseas to 8.75 percent for cash and cash-equivalent profits and 3.5 percent on other profits.

Wells Fargo currently does not have any trade policy changes, such as tariffs, incorporated into their forecast at this time but fully recognize that there is a decent probability of such policies becoming unilaterally enacted by President Trump, at least on a one-off basis.

Need Tax Advice?

 

 

 

Contact the Tax Lawyers at 

Marini& Associates, P.A.  

 

 

for a FREE Tax Consultation

at: www.TaxAid.com or www.OVDPLaw.com or

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

 

 

 

 

U.S. taxpayers who have foreign bank and/or financial accounts should be watching the clock.

According to Tax Analysts Exclusive: Conversations: Koskinen Looks to Future of Tax Administration, IRS Budget, IRS Commissioner John Koskinen stated on December 12, 2016 that, the Offshore Voluntary Disclosure Program (OVDP) will continue at least through November 2017.

• John Koskinen also stated that One of the reasons people have talked about winding it down is trying to encourage people you've got to get in. 
• At some point, it's going to end and then you're going to be stuck with the normal process and you don't want people saying, 'I'll just wait as long as I can.' 
• The real incentive, though, is if we find out about you after we know you exist with the banks, then the penalties and the implications go up significantly. 
• There are other banks in the world (Hong Kong, Singapore, all of Asia) and other areas (besides Switzerland) in the world than just Europe and people who are maybe hiding money in other places ought to take advantage of that disclosure program, because we're coming.

1. The IRS does not have sustainable staffing on its present and prospective budgets.  President Trump recently called for a $239 million cut to the IRS budget in 2018.  The proposed spending cut is similar to a reduction proposed in the House last year and represents about 2% of the budget.  This alone is not enough but taken in conjunction with recent historical budget cuts and/or lack of increased budgets the IRS staffing has decreased 30% over the last couple of years. 
2. The average OVDP takes roughly 2 years to complete from submission to receipt of the closing form 906.  There are multiple administrative, examination, technicians, and managers involved in this process, especially if there is an opt-out.  The amount of time, energy, and resources that the IRS must allocate to this area cannot be sustained.  This is akin to the status of normal IRS audit or examination. In that area, the IRS has been very created and resorted to automated matching and computer generated notices as a substitute to the lack of workforce.
3. The Foreign Account Tax Compliance Act (FATCA) and Intergovernmental Agreements (IGAs) have produced a treasure trove of information that has been exchanged between foreign countries and the US. 

4. The ICIJ Panama Papers which leaked offshore holdings from 1977 to 2015 and revealed 11.5 million records including the holdings of 140 politicians, 214,088 offshore entities, and 33 persons/companies blacklisted by the US government.   

5. IRS Data Mining of the > 100,000 disclosures in the previous and current OVDP programs that the IRS can use the information it receives to conduct new audits. The data mining can be used to:

For those that receive automated notices with FBAR, 8938, and/or other international informational related penalties, they should also consider their options as there are many successful defenses to the assessment of these penalties (See our blog post US Taxpayers Are Receiving Automated $10,000 Penalty Assessments For Late Filed Form 5471's & 5472's - We Can Help)

Whatever your circumstances regarding your unreported offshore income, you should immediately seek a firm that has extensive experience in successfully resolving these types of issues for taxpayers and also has the experience of successfully litigating these types of issues with the IRS.

Do You Still Have Undeclared Income from

Offshore Banks or Financial Advisors?

 

 

 

Want to Know if the OVDP Program is Right for You?

 

Contact the Tax Lawyers at 

Marini& Associates, P.A.  

 

 

for a FREE Tax Consultation

at: www.TaxAid.com or www.OVDPLaw.com or

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

 

 

 

 



Sources:

Tax Analysts 

The Wolf Group
 
Golding & Golding