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John Marien of Andreozzi Bluestein LLP was named to the Tax Notes’ 2013 Person of the Year list. Tax Analysts publishes an annual list of the individuals who have significantly influenced federal tax policy during the past year. John Marien, director of litigation support at Andreozzi Bluestein LLP, was named to Tax Notes’ 2013 Person of the Year list for his role in
In a November 5, 2013 post in The Justice Blog, the United States Department of Justice (DOJ) Tax Division issued a reminder to Swiss Banks that their time is running out to enter into a non-prosecution agreement with the United States. Eligible Swiss Banks have until December 31, 2013 to seek a non-prosecution agreement with the United States. This program is just
By: Gregory D. Verdibello, Esq. Once a taxpayer’s liability has been formally recorded on the books and records of the Internal Revenue Service (“IRS”), the IRS may use one of its collection tools to satisfy the taxpayer’s outstanding liability. Two of the collection tools that the IRS may choose to use are a lien and levy. Many taxpayers do not know the
By: Royston Mendonza Overview Very simply, an Offer in Compromise (“Offer”) is where a Taxpayer “offers” a sum of money to the Internal Revenue Service (“IRS”) to “compromise” a tax debt for less than the total amount owed. Form 433-A To begin an Offer calculation, you must first fill out IRS Form 433-A (OIC). The current version was released in
Dionne Warwick Bankruptcy Case Seeks to Discharge Taxes By: Daniel Brown “Wishin’ and Hopin’”[2] to discharge more than $10.2 million in taxes, Dionne Warwick filed a Chapter 7 personal bankruptcy case in the United States Bankruptcy Court for the District of New Jersey on March 21, 2013. According to her filed bankruptcy petition, the tax debts owed include $6,955,192.03 in personal
By: Gregory Verdibello Unfiled returns can create financial and emotional stress, and can cause criminal issues for many people. It seems that more and more people are failing to file their returns on time, or even file at all. This could be due to lack of records, personal issues, financial issues, or simply just ignoring one’s obligation under the law.
By: Kenneth A. Grossberg Today, United States investors in foreign corporations often find themselves with an unknown or unexpected problem. In particular, investors in mutual funds organized outside of the United States have run into problems with the Passive Foreign Investment Company (“PFIC”) rules. As the application of these rules can result in severe tax consequences to the unwary and unprepared,
The Internal Revenue Service (IRS) and the U.S. Department of Justice (DOJ) continue to actively seek information about U.S. taxpayers with interests in foreign accounts. The IRS and the DOJ sought a “John Doe” summons for the Swiss bank UBS AG. A “John Doe” summons issued to a financial institution generally requests information identifying U.S. taxpayers with account holdings or
August 2012, Buffalo, NY– All five partners of Andreozzi Bluestein LLP have been named to the New York State Super Lawyers list as five of the top attorneys in New York State for 2012. No more than 5 percent of the lawyers in the state are selected by Super Lawyers. Super Lawyers, a Thomson Reuters business, is a rating service of outstanding lawyers
The IRS has announced new procedures to aid voluntary disclosures by taxpayers with undisclosed foreign accounts. The new procedures follow the IRS’ January 9, 2012 announcement of the 2012 Offshore Voluntary Disclosure Program (OVDP). The new procedures will allow for resolution of issues related to foreign retirement plans, such as the Canadian Registered Retirement Savings Plan, including allowance of low compliance risk