Thursday, March 15, 2018

EU Adds Bahamas, Saint Kitts, Nevis and the US Virgin Islands to its BLACKLIST!


The EU Council of Finance Ministers has added:
  1. the Bahamas,
  2. Saint Kitts,
  3. Nevis, and
  4. the US Virgin Islands
to the EU Blacklist of non-cooperative tax jurisdictions. At the same time,
  1. Anguilla,
  2. Antigua and Barbuda,
  3. the British Virgin Islands and
  4. Dominica
have been put on the 'grey list' of jurisdictions that have promised to amend their tax systems in line with EU requirements.

  1. Bahrain,
  2. the Marshall Islands and
  3. Saint Lucia
have been moved from the blacklist to the grey list after giving similar undertakings.

Have An Offshore Tax Problem?
 Want to Know if the OVDP Program is Right for You?
(Ending September 28th)
Contact the Tax Lawyers at 
Marini& Associates, P.A. 
for a FREE Tax Consultation
Toll Free at 888-8TaxAid (888) 882-9243


Mossack Fonseca Closing at End of March - OVDP Ends Sept 28th!

Mossack Fonseca, the firm at the center of the ‘Panama Papers’ affair, has announced it is to close operations at the end of March 2018.

Millions of confidential client documents were stolen from the trust and company service provider in April 2016 and released to the press, triggering a media campaign that led to reputational deterioration and raids on its offices by Panamanian authorities.

At least 150 investigations were opened in 79 countries to examine possible tax evasion and money laundering, according to the US-based Center for Public Integrity.

Founded in 1977 by the German lawyer Jürgen Mossack, it was the world’s fourth-biggest provider of offshore services at the time the scandal erupted. Mossack was joined by the Panamanian lawyer Ramón Fonseca and a third director, the Swiss lawyer Christoph Zollinger, was later added.

Until the publication of the Panama Papers, it had been mostly obscure despite sitting at the heart of the global offshore industry and acting for about 300,000 companies. More than half were registered in British tax havens, as well as, in the UK.

Last month, Panamanian prosecutors raided the offices of Mossack Fonseca, seeking possible links to Odebrecht, Latin America’s largest engineering company. The Brazilian construction firm has admitted to bribing officials in Panama and other countries to obtain contracts in the region between 2010 and 2014.

Ramón Fonseca denied last month that his firm had a connection to Odebrecht, while accusing the Panamanian president, Juan Carlos Varela, of directly receiving money from Odebrecht. Varela has denied that he took any money from Odebrecht.

A few staff will continue to be employed to comply with requests from authorities and others.

Do You Have Undeclared Income 
From A Foreign Company
Formed By Mossack Fonseca ?
 Want to Know if the OVDP Program is Right for You?

(Program Ends September 28th)

Contact the Tax Lawyers at 
Marini& Associates, P.A.    
for a FREE Tax Consultation at:

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





The Guardian


Tuesday, March 13, 2018

IRS Issues FAQ's Regarding How to Report Section 965 Transition Tax on 2017 Tax Returns

On March 13, 2018, the IRS added Questions and Answers about Reporting Related to Section 965 on 2017 Tax Returns on its website. This document provides answers to questions regarding return filing and tax payment obligations arising under section 14103 of “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018,” P.L 115-97 (“the Act”), which was enacted on December 22, 2017.

The new provision enacted by section 14103 of the Act, set forth at section 965 of the Internal Revenue Code (the “Code”), applies with respect to the last taxable year of certain specified foreign corporations (as defined under

In general, section 965 of the Code requires United States shareholders, as defined under section 951(b) of the Code, to pay a transition tax on the untaxed foreign earnings of certain specified foreign corporations as if those earnings had been repatriated to the United States.
section 965(e) of the Code) beginning before January 1, 2018, and the amount included in income under section 965 of the Code is includible in the United States shareholder’s year in which or with which such a specified foreign corporation’s year ends.  Taxpayers may have to pay tax resulting from section 965 of the Code when filing their 2017 tax returns.  For example, section 965 of the Code may give rise to a 2017 tax liability for a calendar year United States shareholder holding an interest in a calendar year specified foreign corporation.

Very generally, section 965 of the Code allows taxpayers to reduce the amount of such inclusion based on deficits in earnings and profits with respect to other specified foreign corporations. The effective tax rates applicable to such income inclusions are adjusted by way of a participation deduction set out in section 965(c) of the Code.

A reduced foreign tax credit applies to the inclusion under section 965(g) of the Code. Taxpayers, pursuant to section 965(h) of the Code, may elect to pay the transition tax in installments over an eight-year period. Generally, a specified foreign corporation means either a controlled foreign corporation, as defined under section 957 of the Code (“CFC”), or a foreign corporation (other than a passive foreign investment company, as defined under section 1297 of the Code, that is not also a CFC) that has a United States shareholder that is a domestic corporation.

The instructions in these FAQs are for filing 2017 tax returns with an amount under section 965 of the Code.
Failure to Submit Tax Returns According to These Instructions May Result in Difficulties in Processing Tax Returns, Including Rejection, Processing Delays, or Erroneous Notices Being Issued.
Taxpayers who electronically file Form 1040 are requested to wait to file their return on or after
April 2, 2018. This will provide the IRS time to make certain system changes to allow the returns to be accepted and processed.
 We Can Advise on How The TCJA Affects You!
Contact the Tax Lawyers at 
Marini & Associates, P.A.  
for a FREE Tax Consultation
Toll Free at 888-8TaxAid (888) 882-9243