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International and Offshore Tax Issues

International Tax & Offshore Issues

International Tax Disputes

The Internal Revenue Service has committed to renewed efforts to pursue international violations of the tax laws by individuals and businesses. In order to address what it considers to be an area rife with abusive tax avoidance behavior, the IRS is aggressively pursuing international tax violations through use of both civil audits and criminal investigations and prosecutions.

The IRS has announced specific plans to focus on combating international tax fraud and tax evasion by expanding its programs of information sharing and cooperation with nations around the world. The IRS’s most recent efforts in this area have been against U.S. taxpayers who maintain unreported foreign bank accounts. The IRS’s and DOJ’s public campaign to identify U.S. taxpayers with accounts in UBS and other foreign banks has been extensively chronicled by the media.

The IRS has also announced that it will focus its efforts on increasing audits of U.S. persons and businesses that make payments to foreign individuals and businesses to ensure the U.S. taxpayers are properly reporting and withholding taxes from those payments. The IRS also plans to increase audits and investigations of U.S. individual and business taxpayers with foreign sourced income, foreign bank accounts and foreign trusts. To accomplish these goals, the IRS announced it plans to hire as many as 800 new employees to focus solely on international tax compliance issues.

At Marini & Associates PA, we specialize in representing the following taxpayers with international tax issues:

  •    U.S. citizens living and working abroad
  •    U.S. citizens with foreign-sourced income
  •    U.S. taxpayers with international trusts
  •    Non-U.S. taxpayers with U.S.-sourced income
  •    International businesses with U.S. tax reporting requirements and tax liabilities
  •    U.S. and Non-U.S. entertainers with worldwide income
  •    Expatriates
  •   U.S. Citizens & Residents with undeclared income from



Handling All International Tax Needs

At Marini & Associates Offices, we understand the complicated interplay of U.S. and international tax requirements and the impact certain foreign-based accounts and assets have on your U.S. tax liability. For more than 34 years, our founding tax attorney Ronald A. Marini, is also an accountant and was 1 of 15 World Wide International Tax Specialists for Arthur Andersen & Co for 11 years prior to forming Marini & Associates, P.A., has been providing clients throughout the world with thoughtful, strategic advice regarding complex tax issues and areas of potential disputes.

With a thorough understanding of U.S. tax laws, finance and international issues, Marini & Associates, P.A. effectively assesses and aggressively seeks to help you avoid or mitigate international tax problems.

Unlike other countries, U.S. taxpayers, whether as individuals or businesses, are taxed on their worldwide income. At Marini & Associates, P.A., we strive to help you avoid any civil and criminal penalties associated with failure to comply with the numerous reporting requirements or failure to report and/or pay taxes on your worldwide income.

If you have been contacted by the IRS regarding international reporting and/or tax liability issues, contact Marini & Associates PA today for assistance representing and defending your international activities or call us at (305) 374-4424 in Miami or toll free at (888) 882 9243.

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