Monthly Archives: October 2025

Chambers, the world’s leading legal ranking and insights intelligence company, has spent over 30 years identifying and ranking exceptional legal talent through an unparalleled research methodology. Its rankings are based on independent and impartial market analysis, assessing law firms and lawyers across more than 200 jurisdictions worldwide. 

“This recognition reflects our unwavering commitment to delivering sophisticated tax law solutions and exceptional client service,” said Ronal A. Marini, Managing Partner of Marini & Associates, PA.

 “We take pride in offering clients the expertise and strategic capabilities that rival the largest firms, while providing the personalized attention that sets us apart.”

The Chambers Florida Spotlight Guide highlights law firms that embody excellence, leadership, and innovation within their fields. Being selected in this prestigious guide underscores Marini & Associates, PA’s reputation for results-driven legal counsel in complex tax matters, including IRS disputes, international tax compliance, estate planning, and corporate tax strategies.

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 Have an IRS Tax Problem?

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

Read more at: Tax Times blog

A Texas federal court has ruled that the U.S. government may foreclose on the home of a physician and his wife in El Paso to help satisfy over $2 million in unpaid federal income taxes. The case, United States of America v. Aranda et al., case number 3:24-cv-00394 in the U.S. District Court for the Western District of Texas, highlights aggressive enforcement where taxpayers fail to file or pay for extended periods.

Dr. Manuel Aranda Jr., a physician, and his wife, Melissa Marie Aranda, a realtor, accrued tax debts totaling approximately $2.1 million, including interest and penalties. The IRS asserted that the couple failed to file federal income tax returns or pay any federal income tax from at least 2013 through 2022. A federal tax lien was placed on their principal residence in El Paso in 2019, setting the stage for further collection action.

U.S. District Judge Kathleen Cardone granted a default judgment after the Arandas failed to respond to the government’s lawsuit. This judgment allows the government to proceed with foreclosure and sale of the property, with the proceeds to be applied to the outstanding tax liability. The court also awarded the government prejudgment interest at 7% from January and post-judgment interest until the tax debt is paid in full.

 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
or Toll Free at 888 8TAXAID (888-882-9243)

Read more at: Tax Times blog

According to Law360, A Florida magistrate judge recommended an order for the arrest of a dual U.S.-German citizen who has failed to pay about $19.6 million in penalties for undisclosed Swiss bank accounts, holding that imposing additional fines would be "an empty gesture."

U.S. Magistrate Judge Bruce E. Reinhart recommended on September 4, 2025 that the district court issue a bench warrant against Isac Schwarzbaum, who failed to appear in court for an Aug. 28 hearing to determine civil contempt sanctions. The court in December 2023 found Schwarzbaum in contempt for failing to repatriate his assets to pay penalties for unreported offshore accounts.

In recommending a bench warrant for the arrest of Schwarzbaum if he attempts to enter the U.S., Judge Reinhart noted that the U.S. government has conceded that additional fines would be "futile" in securing compliance.

"Mr. Schwarzbaum has failed to repatriate his assets and failed to satisfy an already large money judgment," Judge Reinhart said. "So, imposing escalating fines would be an empty gesture."

In a separate filing, Judge Reinhart said Schwarzbaum's failure to appear in court could also be the basis for criminal contempt. Accordingly, he recommended that the district court refer the case to Florida prosecutors.

U.S. District Judge Beth Bloom in March 2020 concluded that Schwarzbaum showed reckless conduct that amounted to a willful failure to file foreign bank and financial account forms for 2007 through 2009. She issued a final judgment in November 2022 that calculated penalties, interest and late fees, which stood at about $12.5 million in total at the time.

In pushing for a repatriation order, the government said in January 2023 that Schwarzbaum sold his Florida home less than three months after Judge Bloom issued her March 2020 findings. 

 Do You Have Undeclared Offshore 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 contact us at:

www.TaxAid.com or www.OVDPLaw.com 

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

Read more at: Tax Times blog

At the center of the issue is Puerto Rico’s Act 60 program, which exempts bona fide residents from paying federal taxes on Puerto Rico-sourced income, including passive gains such as capital gains. The program, originally passed in 2012, has been widely embraced by high-net-worth individuals seeking to shield crypto and investment profits from the IRS.

Wyden’s letter to Morehead focuses on a billion-dollar Pantera Capital sale that reportedly generated hundreds of millions of dollars in taxable gain. The senator questioned whether the entire transaction was wrongfully classified as Puerto Rico-source income exempt from U.S. tax, even though Morehead may have continued living in San Francisco.

“These are serious allegations of potential abuse of Puerto Rico tax incentives to avoid the payment of U.S. taxes that you must immediately address,” Wyden wrote.

Complicating matters further, Morehead allegedly sought advice from Miami-based tax lawyer Jeffrey Rubinger, whose name surfaced earlier this year in the case of Suresh Gajwani. Gajwani attempted to sidestep $30 million in U.S. capital gains tax through a last-minute Puerto Rico residency claim, only to plead guilty to filing a false return in June.

Wyden is demanding that Morehead disclose details on:

·         All assets sold while claiming Puerto Rico residency

·         The amount of income he reported as Puerto Rico-sourced and exempt

·         The advisers who assisted with his Puerto Rico tax exemption application

·         Whether Rubinger provided a legal opinion regarding the billion-dollar Pantera transaction

So far, Morehead has not cooperated fully with the committee’s requests, heightening suspicions that Puerto Rico’s lucrative tax breaks are being used as a vehicle for large-scale U.S. tax avoidance.

This latest probe highlights both the political and enforcement risks tied to Puerto Rico’s Act 60 program. While enticing for investors, high-profile cases like these suggest heightened IRS and congressional scrutiny and raise new questions about whether the program will survive in its current form.

 Have an IRS Tax Problem?

     Contact the Tax Lawyers at

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

Read more at: Tax Times blog