Heather L. Marello
“But It’s Not My Fault” How to Obtain Innocent Spouse Relief
By: Heather L. Marello Married taxpayers often file their annual income tax returns electing “married filing joint” status. While often beneficial from a tax perspective, spouses rarely understand that, by electing this status, each spouse agrees to be liable for the entire amount due for that year – whether it is the liability reported as due on the return or
Understanding Audit, Issues and Strategies (Part 2)
By: Heather L. Marello, Esq. Types of Audits Pursuant to the IRS Data Book, during calendar year 2016, the IRS audited almost 1.1 million tax returns, or 0.5% of all returns filed. A representative never can (or should) predict to a client whether his or her return will be selected for audit, as a number of factors can cause the
Andreozzi Bluestein LLP Promotes Heather L. Marello to Senior Associate
We are proud to announce the promotion of attorney Heather L. Marello from Associate to Senior Associate. Mrs. Marello focuses her practice on tax controversy and international tax compliance, and also assists in teaching Tax Practice and Procedure at UB Law School, editing chapters for Reuters publication, and was recently published in the Buffalo Law Journal. Mrs. Marello is admitted
FBAR Penalties – The Government’s Coin-Flip Burden of Proof on Willfulness
By: Heather L. Marello, Esq. The Bank Secrecy Act of 1970, Pub. L. 91-507, 84 Stat 114 (Oct. 26, 1970), addressed the government’s desire to monitor the use of foreign bank accounts for illegal activities by authorizing the Secretary of the Treasury to require U.S. citizens, residents, and others to “keep records, file reports, or keep records and file reports,
IRS Relaxes Bona Fide Residency Rules in the Wake of Hurricanes Irma and Maria
By: Heather L. Marello, Esq. In the wake of recent hurricanes that devastated Puerto Rico and the U.S. Virgin Islands, IRS released Notice 2017-56, Physical Presence of Certain Individuals in the Commonwealth of Puerto Rico or the United States Virgin Islands Under Section 937(a) Following Hurricane Irma or Hurricane Maria, to provide relief under the strict bona fide residency rules
Andreozzi Bluestein Attorneys Speak on Federal and State Compliance Issues
Buffalo Law Journal’s Michael Petro interviewed Andreozzi Bluestein’s Senior Associate Michael Tedesco and Associate Heather Schmidt on federal and state compliance issues for his Tax Law Special Report. Petro’s federal article discusses recent trends in foreign bank reporting issues for both U.S. citizens and international banks. The IRS began allowing taxpayers to come forward with respect to their foreign accounts
Law Creates New Due Dates for FBAR and Other Tax and Informational Returns
By: Heather Schmidt On Friday, July 31, 2015, President Obama signed H.R. 3236, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 into law. In addition to temporarily extending funding for Federal-aid highway and infrastructure programs, the law also sets forth new deadlines for certain tax returns and informational filings. Among the notable changes to the revenue
Taxpayer Advocate Service Criticizes IRS’s Offshore Voluntary Disclosure Programs in 2014 Congressional Report
By: Heather L. Schmidt To combat money laundering and evasion of U.S. income obligations through the use of offshore accounts, Congress imposed a requirement on all United States taxpayers to annually file a Report of Foreign Bank and Financial Accounts (“FBAR”)[1] disclosing interests in accounts held outside of the U.S. where the aggregate balances exceed $10,000. However, in 2002 the