Category Archives: criminal tax law

According to Law360, a California district judge ruled that a man owes just over $324,000 in penalties, interest and late fees for failing to report information on his foreign bank accounts to the Internal Revenue Service in U.S. v. Magdi Hanna, case number 8:22-cv-00179, in the U.S. District Court for the Central District of California.

Magdi Hanna never appeared in court to address claims that he deliberately failed to report two Credit Suisse accounts on his taxes in 2010, 2011 and 2012, leading the judge to take them as true and enter a default judgment against him Wednesday.

Federal prosecutors previously said Hanna also did not report interest or dividends from the accounts, which held at least $7 million in 2010 and $6 million in 2011 and 2012.

Described by prosecutors as an educated business owner with an advanced degree in chemical engineering, Hanna opened the accounts in the name of two corporations he owned or controlled, according to court filings.

Have an FBAR Penalty Problem?  

 

 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

Read more at: Tax Times blog

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

Read more at: Tax Times blog

The IRS Chief Counsel's Office has issued Program Manager Technical Advice 2022-006, that 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?

     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

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

Sincerely,

Ronald A. Marini, Esq. &
Anita W. Friedlander, Esq.
Marini & Associates PA
Miami
888 8TAXAID
888 882-9243
www.TaxAid.com

Read more at: Tax Times blog