Marini & Associates PA

Marini & Associates PA WE ARE AN INTERNATIONAL & TAX LITIGATION LAW FIRM. M&A is a leader in providing International Tax Ad

Tax Court: A Corporate Offer-in-Compromise Can Cap the Owner's Trust Fund Penalty
10/07/2026

Tax Court: A Corporate Offer-in-Compromise Can Cap the Owner's Trust Fund Penalty

Business owners in a cash crunch often make the same choice: keep the crew paid, keep the unions satisfied, keep the doors open, and deal wi...

No Joint Return, No Innocent Spouse Relief
10/02/2026

No Joint Return, No Innocent Spouse Relief

On September 28, 2026, the U.S. Tax Court issued a short but instructive memorandum opinion in Daidone v. Commissioner, T.C. Memo. 2026-98. ...

Missed a QEF Election? PLR 202636015 Shows the IRS Will Still Say Yes When You Relied on Your Accountant
09/18/2026

Missed a QEF Election? PLR 202636015 Shows the IRS Will Still Say Yes When You Relied on Your Accountant

Private Letter Ruling 202636015 (issued June 8, 2026; released September 4, 2026) The short version A domestic limited partnership discovere...

$2.9 Million FBAR Penalty Upheld by the Fourth Circuit and What it Means for Anyone with an Unreported Foreign Bank Acco...
09/16/2026

$2.9 Million FBAR Penalty Upheld by the Fourth Circuit and What it Means for Anyone with an Unreported Foreign Bank Account

If you have ever opened a bank account outside the United States, for a business, an inheritance, or just because it was convenient while li...

Treasury and IRS Propose New Rules for Allocating Deductions to GILTI/NCTI Income Under the OBBBA
09/11/2026

Treasury and IRS Propose New Rules for Allocating Deductions to GILTI/NCTI Income Under the OBBBA

On September 10, 2026, the Treasury Department and the IRS released proposed regulations under REG-117273-25 , scheduled for publication in ...

IRS Watchdog Finds Nonfiler Program Riddled With Gaps — What It Means for Taxpayers Who Haven't Filed?
09/04/2026

IRS Watchdog Finds Nonfiler Program Riddled With Gaps — What It Means for Taxpayers Who Haven't Filed?

If you have unfiled tax returns sitting in a drawer somewhere, a new federal watchdog report is worth your attention. On August 31, 2026, th...

The Year-End CFC Sale Loophole Just Closed — Here's What Replaces It
09/02/2026

The Year-End CFC Sale Loophole Just Closed — Here's What Replaces It

On August 25, 2026, the U.S. Treasury Department and the IRS released long-awaited proposed regulations (REG-115646-25) implementing sweepin...

Got an IRS Notice in the Virgin Islands? Don't Ignore This Filing Notice
08/28/2026

Got an IRS Notice in the Virgin Islands? Don't Ignore This Filing Notice

If you are a bona fide resident of the U.S. Virgin Islands, you generally file your income tax return with the Virgin Islands Bureau of Inte...

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