Yearly Archives: 2017

According to Law360, President Donald Trump's former campaign chairman, Paul Manafort, and an alleged co-conspirator have been indicted on charges of conspiracy against the United States, money laundering and bank records charges tied to close to a decade of secret lobbying on behalf of Russia-associated Ukrainian officials.

The indictment alleges that Manafort and Gates contracted two D.C. area lobbying firms during a multimillion dollar lobbying campaign, telling them they would be representing the government of the Ukraine. The two men allegedly directed lobbying to members of Congress and the administration on behalf of Ukraine without declaring as foreign agents.

End Your Criminal Exposure for Having Undeclared Income

From Your Foreign Account?

 

 

 Want to Know if Which 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 

On September 5, 2017 posted How Will the IRS Know About My Foreign Account? where we discussed that Taxpayers who have financial assets outside the United States often ask the question "How will they (IRS) know about my Foreign Account?;" when they are considering how (or whether) to come clean and inform the IRS about their previously undisclosed foreign financial accounts.

Since 2008,  a string of scandals involving foreign banks and investigations by the U.S. government into various non-U.S. financial institutions has garnered international media attention and changed the way governments around the world deal with offshore financial accounts.

 

And Now Appleby's Recent Data Breach is yet Another Example of How the IRS Can Discover your

 Unreported Foreign Account!

 

The Super-rich clients of offshore law firm Appleby are bracing themselves for the exposure of their financial secrets, after the firm admitted data had been stolen in a cyber attack last year.

 

The Bermuda-based law firm admitted it was "not infallible" and said some client data had been stolen in the hack, but denied any wrongdoing.

The International Consortium of Investigative Journalists (ICIJ) has since approached the firm with allegations of wrongdoing, after it was handed data obtained in the hack, which Appleby strongly refutes.

Appleby said in a statement it did not tolerate "illegal behaviour," and said the ICIJ's allegations were "unfounded and based on a lack of understanding of the legitimate and lawful structures used in the offshore sector."

 

Marini & Associates, PA has assisted several hundred clients with coming into U.S. tax compliance and avoiding the draconian penalties that the IRS may impose on U.S. persons with undisclosed foreign accounts.

Do You Have Undeclared Foreign Income?

 

  

 Want to Know if Which 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

• Appleby
• Business Insider
• Daily Telegraph (Paywall)

We previously posted on December 1, 2016 Panama Papers - Global Effects Thus Far & Continuing Impact  where we discussed that on April 4, 2016 we initially posted Huge Leak From the Panamanian Law Firm Mossack Fonseca! discussing 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.

Then Fast-forward 8 months later to December 1, 2016 and the investigation has produced an almost daily drumbeat of regulatory moves, follow-up stories and calls by politicians and activists for more action to combat offshore financial secrecy and ICIJ recently posted Panama Papers Have Had Historic Global Effects — and the Impacts Keep Coming where they cover the following repercussions:

• At least 150 inquiries, audits or investigations into Panama Papers revelations have been announced in 79 countries around the world
• An estimated $135 billion was wiped off the value of nearly 400 companies after the Panama Papers
• Governments are investigating more than 6,500 taxpayers and companies, and have recouped at least $110 million so far in unpaid taxes or asset seizures
• Nine Mossack Fonseca offices have shuttered around the world, and the law firm has been fined close to half a million dollars.

Now the Panama Papers has taken a Human Toll!

“My mother was assassinated because she stood between the rule of law and those who sought to violate it, like many strong journalists,” Matthew Caruana Galizia, who is also an investigative reporter, wrote in a moving and at times graphic Facebook post.

“But she was also targeted because she was the only person doing so. This is what happens when the institutions of the state are incapacitated: the last person left standing is often a journalist. Which makes her the first person left dead.”
Dutch forensic experts and a team from the FBI were due to arrive in Malta to help police in the EU’s smallest state investigate the killing of Caruana Galizia, who led the Panama Papers investigation into corruption on the island.

Do You Have Undeclared Foreign Income? 

 

 

 

 

 

 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:

Private Wealth

The Guardian

 

 

Where you represent as many taxpayers as we do in relation to cleaning up their previously undeclared offshore investments and bank accounts, your are on the IRS' website daily to review the current elements required by the IRS to qualify for an OVDP filing or an OVDP streamline filing. (See www.OVDPLaw.com). 

You can imagine my surprise when my desktop link to each relevant IRS OVDP page, that I've been using for the last 8 years no longer worked.
 
The IRS has changed its entire website to be more user-friendly, with the goal of allowing individuals to access the IRS' website and handle their tax liabilities individually like they currently do with their bank account. This is described as IRS Future State.  We previously discussed this in our blog post Mid-Year National Tax Advocate's Report is Wary of IRS' “Future State.”

According to the IRS "Within our tight budget constraints, the IRS has also continued to analyze and develop plans for improving how the agency can fulfill its mission in the future... In requesting adequate resources to allow the IRS to improve taxpayer service, it is important to point out that our goal is not to fund today’s staff functions at historically high levels.

We need to be, and are, looking forward to a new, improved way of doing business that involves a more robust online taxpayer experience. This is driven, in part, by business imperatives; when it costs between $40 and $60 to interact with a taxpayer in person, and less than $1 to interact online, we must reexamine how we provide the best possible taxpayer experience, in response to taxpayer expectations and demands.

So where can you the Tax Advisor now find the necessary links to determine what the IRS' current requirements for OVDP filing or an OVDP streamline filing are, as well as the requirements for late filed information return?

Below we have provided the new links to the following replacement pages:

1. 2012 Offshore Voluntary Disclosure Program
2. Offshore Voluntary Disclosure Program Submission Requirements
3. How to Make an Offshore Voluntary Disclosure
4. Streamlined Filing Compliance Procedures
5. Delinquent FBAR Submission Procedures and
6. Delinquent International Information Return Submission Procedures

Technical Positions taken at IRS Appeals or in Tax Court!

However, as a practice point, you should also remember to print out the current IRS screen describing the procedure which are undertaking for a particular client when making one of the above-mentioned filings. This way you can prove the list of IRS requirements at the time you made the filing, as these requirements are constantly changing, which will allow you to prove that you fulfilled the requirements at the time you filed on behalf of your client.

Do You or Your Client Have Undeclared Foreign Income?

 

 Want to Know if Which 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