Marini & Associates PA

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

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...

IRS Levy Trumps Bid to Recover Seized Bitcoin
08/21/2026

IRS Levy Trumps Bid to Recover Seized Bitcoin

A recent Colorado federal district court decision underscores a critical point for taxpayers with seized digital assets: once the IRS levies...

IRS Authority Under Fire: New Court Ruling Limits Treasury’s Regulatory Reach
07/31/2026

IRS Authority Under Fire: New Court Ruling Limits Treasury’s Regulatory Reach

Ruling May Further Erode IRS Authority After Loper Bright A recent decision by the U.S. Court of Federal Claims, Keysight Techs., Inc. v....

US Expatriations Up 68.5% I From Last Year
07/24/2026

US Expatriations Up 68.5% I From Last Year

Are You Tired of Trump 2.0. That The Republicans Now Control the House & the Senate. Are You Sick of Liberal Democrats Trying to Revise Soci...

Tellock Reinforces the Importance of Filing Compliance in CDP
07/22/2026

Tellock Reinforces the Importance of Filing Compliance in CDP

Don M. Tellock failed to file income tax returns for 2016 and 2017. In response, the IRS prepared a Substitute for Return (SFR) for each yea...

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