Yearly Archives: 2018

Now According to Law360, Michael “The Situation” Sorrentino, a performer on the reality TV series “Jersey Shore,” was ordered on October 5, 2018 to serve 8 months behind bars for tax evasion, with a New Jersey federal judge rejecting his bid to stay out of prison.

U.S. District Judge Susan D. Wigenton handed down that sentence after Sorrentino pled guilty in January to a single count of tax evasion. Before his sentencing, the judge sentenced Sorrentino’s brother, Marc, to 2 years in prison following his own guilty plea in January to one count of aiding in the preparation of a false and fraudulent tax return.

Authorities have alleged that the Sorrentinos created businesses, such as MPS Entertainment LLC and Situation Nation Inc., that earned money from various sources, such as promotional appearances and the publication of a comic book featuring Michael Sorrentino as a superhero.

Among other allegations, authorities said the brothers failed to pay all of the federal income tax owed on about $8.9 million they earned between 2010 and 2012.

In pleading guilty to the tax evasion charge on Jan. 19, Michael Sorrentino admitted that he earned taxable income during tax year 2011, including funds paid in cash, and he took steps to conceal some of his income to avoid paying the full amount of the taxes he owed.

Sorrentino said he made cash deposits into bank accounts in amounts less than $10,000 each to prevent the transactions from coming to the attention of the Internal Revenue Service.

With his own guilty plea that day, Marc Sorrentino admitted to willfully providing false information in assisting his accountant in preparing his income tax return for tax year 2010. That false tax return underreported his partnership income, total income and taxable income, Sorrentino said. He also has admitted to a tax loss attributable to him for tax years 2010, 2011 and 2012.

The brothers’ former accountant, Gregg Mark, has admitted to filing false tax returns on their behalf. Mark pled guilty in December 2015 to one count of conspiracy to defraud the United States, admitting that he prepared fraudulent tax returns for the Sorrentinos for tax years 2010 and 2011. He is awaiting sentencing.

Contact the Tax Lawyers of

Marini & Associates, P.A.    

 

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www.TaxAid.com or www.OVDPLaw.com or

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

The notice of proposed rulemaking providing rules under section 965 published in the Federal Register on August 9, 2018, provided, among other things, for a basis election to be made by United States shareholders in certain circumstances. The guidance impacts proposed regulations issued in August 2018.
 Under the guidance:

1. U.S. shareholders are allowed an extended time to make the basis adjustment election under the reduction rules of Code Sec. 965(b). This Notice 2018-78 announces that the due date for the basis election that would otherwise be required to be made before the final regulations are published will be extended to 90 days after the publication of the final regulations. Further, elections made in the interim will be revocable.
2. A more taxpayer favorable rule will be included in the final regulations for determining the aggregate foreign cash position of a U.S. shareholder that is a member of a consolidated group. The determination of the aggregate foreign cash position of a United States shareholder that is a member of a consolidated group, which were inconsistent with the more taxpayer-favorable rule announced in Notice 2018-07. and
3. U.S. shareholders affected by Hurricane Florence are provided an extended period to file election statements and transfer agreements. This Notice 2018-78 provides a postponement for taxpayers affected by Hurricane Florence to make elections, and file transfer agreements, related to section 965. 

The proposed regulations generally provide that a U.S. shareholder’s basis in its stock or property of the deferred foreign corporation (DFIC) is increased by the amount of the U.S. shareholder’s Code Sec. 965(a) inclusion amount with respect to the DFIC. The amount that would otherwise be included under subpart F may be reduced under Code Sec. 965(b) if the taxpayer is a U.S. shareholder with respect to at least one DFIC and one E&P deficit foreign corporation. In general, no adjustments to the basis of stock or property are made to take into account the reduction of the Code Sec. 965(a) earnings amount under the reduction rules. A taxpayer may, however, elect to make relevant basis adjustments as a result of the reduction rules in certain circumstances.

 

for a FREE Tax HELP Contact us at:

www.TaxAid.com or www.OVDPLaw.com or Toll Free at 888-8TaxAid (888) 882-9243

Sources:

 

Notice 2018-78 

 

CCH