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Monthly Archives: July 2022

Want to Expatriate? How About Panama?

Increasing numbers of internationally mobile entrepreneurs and knowledge workers are relocating to Panama, drawn by its political stability, high growth economy, and strategic location with excellent connectivity to Central, South and North American markets.

When you add its “all-time-summer” climate and high quality of life you can see why it’s also a preferred destination for retirees, with Panama recently named the number one place to retire in International Living Magazine’s 2022 Annual Global Retirement Index.

Panama operates a number of easily understandable and efficiently operated temporary and permanent residency schemes, all of which offer the right to live and study in Panama. Panama operates a territorial tax regime, meaning that income sourced outside of Panama is not taxed in Panama.

The Digital Nomad Visa
Introduced in response to changes in working patterns triggered by the global pandemic, Panama’s digital nomad visa allows remote workers from abroad to reside in Panama for an initial nine months, with the option to extend this for another nine. Panama’s position as an international logistics centre means that it has excellent internet connectivity, with one of the highest average download speeds in Latin America.

Applicants for the digital nomad visa need to:

1.  Have valid health insurance for the duration of their stay in Panama.

2.  Show proof of existence of the foreign company they work for, in the place where it is registered.

3.  Provide a letter issued by the legal representative of the company detailing the applicant’s position and functions, monthly income and remote work modality, with a commitment to assume the expenses of return or repatriation if this becomes necessary. Self-employed applicants must provide a sworn declaration instead of the letter, with additional supporting documentation.

Permanent Residency
Panama offers several options to obtain permanent residency, with the possibility of subsequently becoming a Panamanian citizen. The two easiest ways to obtain permanent residency are to apply through the ‘Friendly Nations’ scheme or as a Qualified Investor.

·     The ‘Friendly Nations’ scheme offers residency to citizens of qualifying nations, of which there are currently 50, if they make a real estate investment of USD200,000.

·     A Qualified Investor can obtain residency through one of three investment routes:

1.  A real estate investment of USD300,000 (until 15 October 2022, after which the amount will increase to USD500,000); or

2.  A stock exchange investment of USD500,000; or

3.  A fixed-term banking deposit of USD750,000.

Qualified Investor applications are processed within 30 days, with it taking between four and six months under the Friendly Nations scheme.

Should I Stay or Should I Go?

Need Advise on Expatriation?


Contact the Tax Lawyers at 
Marini & Associates, P.A.   

for a FREE Tax Consultation contact us at:
www.TaxAid.com or www.OVDPLaw.com 
Toll Free at 888-8TaxAid (888) 882-9243






Read more at: Tax Times blog

Tech Advice 2022-006 Clarifies Collection Efforts on Non-US Asset

The IRS Chief Counsel's Office has issued Program Manager Technical Advice 2022-006that answers employee questions about collecting on a delinquent taxpayer's assets that are outside the U.S.

The Advice addresses, in a question-and-answer format, when it's appropriate for the IRS to simultaneously pursue certain collection actions against a taxpayer that has been issued a tax bill, but has refused or neglected to pay it, and the IRS has exhausted domestic assets to levy. 

According to the Advice, the IRS generally isn't prohibited from pursuing multiple collection actions simultaneously. However, two specific collection actions that shouldn't be taken simultaneously: 1) issuing the taxpayer a notice of intent to request passport revocation (Letter 6152), and 2) actually referring the taxpayer to the State Department for revocation. The letter must be issued first and the time for responding to the letter must expire before the State Department referral.

Also, once a taxpayer's debt has been referred for litigation, no collection actions should be taken without approval from the Chief Counsel's Office and/or the Justice Department, the Advice noted.

In addition, the Advice explained the appropriate use of databases set up under the Foreign Account Tax Compliance Act (FATCA) when trying to identify offshore assets that can be used for collection. Generally, FATCA databases may be used to identify assets for collection, the Advice noted. 

However, the authorized uses of some FATCA data sets may vary depending on whether the data was received under an international tax information sharing agreement. A few international agreements restrict the use of tax information for tax periods that predate the effective date of the agreement or require the IRS to obtain authorization before publicly disclosing shared information in a collection proceeding.

Have an IRS Tax Problem?

Concerned That the IRS Levy Your Foreign Assets?

Contact the Tax Lawyers at

Marini & Associates, P.A. 

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
Toll Free at 888 8TAXAID (888-882-9243)


Read more at: Tax Times blog

Join us for “Pre-Immigration Estate and Gift Tax Planning: Foreign Assets, Reporting Requirements, Strategies for Estate Planners”

Strafford Webinars

I am pleased to announce that I will be speaking in an upcoming Strafford live video webinar, "Pre-Immigration Estate and Gift Tax Planning: Foreign Assets, Reporting Requirements, Strategies for Estate Planners" scheduled for Tuesday, September 27, 1:00pm-2:30pm EDT. Because of your affiliation with my firm, you are eligible to attend this program at half off. As long as you use the links in this email, the offer will be reflected automatically in your cart.

Our panel will provide trusts and estates attorneys with a practical guide to pre-immigration estate planning tools and techniques. The panel will go beyond the basics to detail intricate strategies for minimizing income tax, including basis strategies for non-U.S. situs assets, structuring "drop-off" trusts, and planning for the possibility of the nonresident alien's return to the country of origin.

After our presentations, we will engage in a live question and answer session with participants so we can answer your questions about these important issues directly.

I hope you'll join us.

For more information or to register >

Or call 1-800-926-7926
Ask for Pre-Immigration Estate and Gift Tax Planning on 9/27/2022
Mention code: ZDFCA


Ronald A. Marini, Esq. &
Anita W. Friedlander, Esq.
Marini & Associates PA

888 882-9243

Read more at: Tax Times blog

No Equivalent Hearing When Taxpayer Timely Requests A Collection Due Process Hearing

The Tax Court in Ruhaak, (11/16/2021) 157 TC No. 9 has found that a taxpayer that timely requested a collection due process hearing could not also request an equivalent hearing.

The IRS sent taxpayer a Notice of Intent to Levy and Notice of Your Right to a Hearing (levy notice). The taxpayer requested a hearing regarding the proposed levy by submitting to the IRS Office of Appeals (Appeals) a Form 12153, Request for a Collection Due Process or Equivalent Hearing. The taxpayer mailed and Appeals received the Form 12153 before the expiration of the 30-day period following the mailing date of the levy notice, during which the taxpayer had a statutory right to request a collection due process (CDP) hearing. (Code Sec. 6330(a)(2) and Code Sec. 6330(a)(3).

The taxpayer had checked a box on the Form 12153 to request an equivalent hearing in the event that his request for a CDP hearing was untimely. Under the applicable regs, a taxpayer who fails to make a timely request for a CDP hearing may request an equivalent hearing instead, provided that the request for an equivalent hearing is made in writing within the one-year period commencing on the day after the date of the levy notice. (Reg §301.6330-1(i)(1) and Reg §301.6330-1(i)(2), Q&A I7)

Appeals Determined That The Taxpayer Timely
Requested A CDP Hearing And, Thus,
Was Not Entitled To An Equivalent Hearing.

Following the CDP hearing, Appeals issued to the taxpayer a notice of determination that sustained the proposed levy.

The taxpayer argued, however, that Appeals should have granted him an equivalent hearing because his Form 12153 constituted a written request for an equivalent hearing made within the one-year period provided for requesting an equivalent hearing.

The Tax Court Held That The Taxpayer's Request For A
Hearing Made Before The Expiration Of The 30-Day Period Following The Mailing Date Of The Levy Notice Necessarily Triggered A CDP Hearing And Not An Equivalent Hearing.

The Court looked to Reg §301.6330-1(i)(1), which provides in relevant part: "A taxpayer who fails to make a timely request for a CDP hearing is not entitled to a CDP hearing. Such a taxpayer may nevertheless request an administrative hearing with Appeals, which is referred to * * * as an 'equivalent hearing.'"

The phrase "[s]uch a taxpayer," the Court found, limits the class of taxpayers who may request an equivalent hearing to those described in the immediately preceding sentence, that is, those who "fail[] to make a timely request for a CDP hearing". In other words, the Court concluded, only those taxpayers who fail to timely request a CDP hearing are eligible to request an equivalent hearing.

Have an IRS Tax Problem?

     Contact the Tax Lawyers at

Marini & Associates, P.A. 

for a FREE Tax HELP Contact us at:
www.TaxAid.com or www.OVDPLaw.com
Toll Free at 888 8TAXAID (888-882-9243)


Read more at: Tax Times blog

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