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Panama Papers – Global Effects Thus Far & Continuing Impact

December 1, 2016

On April 4, 2016 we posted Huge Leak From the Panamanian Law Firm Mossack Fonseca! where we discuss 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.
 
They show how Mossack Fonseca has helped clients launder money, dodge sanctions and evade tax. The company says it has operated beyond reproach for 40 years and has never been charged with criminal wrong-doing.

Gerard Ryle, director of the ICIJ, said at the time, that the documents covered the day-to-day business at Mossack Fonseca over the past 40 years.

While no reference was initially made regarding U.S. clients; we correctly speculated that U.S. persons will probably show up, given that Mossack Fonseca apparently maintained a branch in Las Vegas, Nevada, under the name of M.F. Company Services and Mossack Fonseca Company Services was currently attempting to fight a subpoena brought in the U.S. District Court for the District of Nevada seeking information on at least 123 companies that it created.

 
Fast-forward 8 months later 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 
 
Our Blog "The Tax Times" lists the following as fallout from the Mossack Fonseca a/k/a "Panama Papers" leak:
Tax Authorities to Have Access to Beneficial Ownership Information By 2018!
 
 
 
 
11/23/16
More & More Fallout From the "Panama Papers"!
 
 
 
 
10/7/16
Europe Begins Inquiry into 'Panama Papers' & 'Bahamian Papers' - How Long Before You Are Discovered?
 
 
 
 
9/29/16
Your Offshore Confidential Information Is Being Delivered Daily to Tax Authorities - New Leak of Bahamian Offshore Files!
 
 
 
 
 
 
9/23/16
More fallout from the "Panama Papers" - Commercial Bank of Taiwan To Pay a $180 Million Penalty
 
 
 
 
8/30/16
Federal Agents & Prosecutors Now Gearing Up to Utilize "Panama Papers" in Their Prosecutions of Mossack Fonseca's Employees!
 
 
 
 
8/9/16
Tax Havens Coming Clean and Becoming Transparent
 
 
 
 
 
7/25/16
Federal Agents & Prosecutors Gearing Up to Utilize "Panama Papers" in Their Prosecutions
 
 
 
 
6/25/16
Nevada & Wyoming Asked to Provide Information on Entities Linked to the “Panama Papers”
 
 
 
 
6/25/16
HM Treasury Published a List of 41 Countries Which Are Committed to Share Beneficial Ownership Information
 
 
 
 
6/15/16
An Analysis of >1,000 American-Based Mossack Fonseca Companies Further Supports That The US Is a New Tax Haven
 
 
 
 
6/3/16
Mossack Fonseca Closing 3 Branch Offices in European Tax Havens
 
 
 
 
6/3/16
Offshore Banks Liability For Client's Tax Evasion
 
 
 
 
5/24/16
EU's Says Tax Avoidance Advisers Must Be Punished - Does That Apply to US Advisors?
 
 
 
 
5/18/16
Mossack Fonseca Affected Taxpayers with Potential Exposure Should Consult with Counsel To Consider Their Legal Options Now!
 
 
 
 
5/11/16
The Saga of the "Panama Papers" Has Only Just Begun!
 
 
 
 
5/10/16
2015 Posts the Deepest Decline in Offshore Investments in 10 years!
 
 
 
 
5/5/16
Mossack Fonseca Law Firm Leak & Attorney-Client Privilege
 
 
 
 
4/26/16
DoJ Launches Criminal Investigation of Hundreds of US Taxpayers Named in Panama Papers Leak!
 
 
 
 
4/25/16
Have An Un-Reported Account Associated With Mossack Fonseca? Like Your Freedom? Call Us!
 
 
 
 
4/18/16
US Pressured For Beneficial Ownership Rules
 
OECD Ready to Act on Leaks From Panamanian Law Firm Mossack Fonseca
 
 
 
 
4/11/16
Get Ready For The US Proposed Plan to Require Banks to Identify Owners of Shell Companies!
 
 
 
 
4/7/16
Huge Leak From the Panamanian Law Firm Mossack Fonseca!
 
 
 
 
4/4/16
 
 
 
 
4/15/16
 
Do You Have Undeclared Income 
From A Foreign Company
Formed By Mossack Fonseca ?
 

 
 
 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

 

 

 

Read more at: Tax Times blog

Set up Your 2017 Calendar to Reflect New Filing Dates for 2016 US Tax Returns

November 29, 2016

On July 31, 2015, President Obama signed into law P.L. 114-41, the “Surface Transportation and Veterans Health Care Choice Improvement Act of 2015,” which includes a number of important tax provisions, including revised due dates for partnership, S corporations and C corporation returns and revised extended due dates for some returns.


Revised Due Dates for Partnership, S &C Corporation Returns 

Under the new law, there is a major restructuring of entity return due dates, effective generally for returns for tax years beginning after Dec. 31, 2015:

  • Partnerships and S corporations will have to file their returns by the March 15th following the end of the tax year. This results in the filing deadline for partnerships being accelerated by one month with the filing deadline for S corporations staying as March 15. 

    • By having most partnership returns due one month before individual returns are due, taxpayers and practitioners will generally not have to extend, or scurry around at the last minute to file, the returns of individuals who are partners in partnerships.

  • C corporations will have to file by April 15th after the end of the tax year resulting in the filing deadline for C corporations being deferred for one month.

These changes to the filing deadlines generally go into effect for 2016 returns. Under a special rule for C corporations with fiscal years ending on June 30, the change is deferred for ten years and it won't apply until tax years beginning after Dec. 31, 2025. 
 


 Revised Extended Due Dates for Various Returns

Taxpayers who can't file a tax form on time, can request an extension to file the requisite form. Effective for tax returns for tax years beginning after Dec. 31, 2015, the new law directs the IRS to modify its regulations to provide for a longer extension to file a number of forms, including the following:

 

  • Form 1065 - U.S. Return of Partnership Income will have a maximum extension of 6 months. The extension will end on Sept. 15 for calendar year taxpayers.

  • Form 1041 -U.S. Income Tax Return for Estates and Trusts will have a maximum extension of 5 1/2 months. The extension will end on Sept. 30 for calendar year taxpayers.

  • The Form 5500 - Annual Return/Report of Employee Benefit Plan will have a maximum automatic extension of 3 1/2. The extension will end on Nov. 15 for calendar year filers.

FinCEN Report Due Date Revised
Taxpayers with a financial interest in or signature authority over certain foreign financial accounts must file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). Currently, this form must be filed by June 30 of the year immediately following the calendar year being reported, and no extensions are allowed.
Under the new law, for returns for tax years beginning after Dec. 31, 2015, the due date of FinCEN Report 114 will be Apr. 15, with a maximum extension of 6 months ending on Oct. 15. The IRS may also waive the penalty for failure to timely request an extension for filing the Report, for any taxpayer required to file FinCEN Form 114 for the first time.

Form 3520 And Form 3520-A Due Date Revised
Form 3520-A is now due on March 15th and will have a maximum extension of 6 months until September 15th.

The IRS or FinCEN need to provide clarification on the format or forms for such extensions, which may be similar to Form 4868, which is the form for requesting extensions on Individual tax returns currently. There may also be a requirement that these extensions be filed on the BSA Website as in the case of the FBAR forms.

 Have a Tax 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

Alert Your Clients to Possible Refund Delays in 2017

November 23, 2016

Tax professionals should alert their clients that a new law requires the IRS to hold refundsuntil mid-February 2017 for people claiming the Earned Income Tax Credit or the Additional Child Tax Credit.

In addition, new identity theft and refund fraud safeguards put in place by the IRS and the states may mean some tax returns and refunds face additional review.

 
 
 
 
 
Have a Tax Problem?
 
 
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

7th Circuit Court of Appeal Reduces Options For Appealing IRS Levies

November 23, 2016

According to Law360  -- Rejecting tax court precedent, the Seventh Circuit ruled Friday that delinquent taxpayers who weren't properly notified of Internal Revenue Service levies still have to pursue an administrative appeal before they can petition the tax court to invalidate the levy.

Acknowledging the difficulty it presents to taxpayers, the Seventh Circuit nevertheless found tax courts don’t have jurisdiction to rule on petitions to invalidate levies unless the taxpayer went to the IRS Office of Appeals first and received a notice of determination.

The case is Kerry Adolphson v. Commissioner of Internal Revenue, case number 15-2242 in the Seventh Circuit Court of Appeals.

Have a Tax Problem?
 
Don't Hide The Your Head In The Sand
 
 
 
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

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