Marini & Associates PA

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

Robocall Fundraiser’s Estate On The Hook For $4.3M In Payroll Taxes
05/20/2026

Robocall Fundraiser’s Estate On The Hook For $4.3M In Payroll Taxes

On May 15, 2026, the U.S. District Court for the Eastern District of Michigan entered judgment in United States v. Estate of Richard T. Cole...

Federal Court Upholds IRS Penalty Power On Foreign Wedding Gifts: Zhang v. IRS
05/15/2026

Federal Court Upholds IRS Penalty Power On Foreign Wedding Gifts: Zhang v. IRS

A recent decision from the U.S. District Court for the Northern District of California adds a major new chapter to the running fight over in...

IRS Offers Reduced Penalties in New Conservation Easement Settlement Program
05/15/2026

IRS Offers Reduced Penalties in New Conservation Easement Settlement Program

In IR-2026-65 t he IRS has released a new, time-limited settlement initiative for taxpayers involved in conservation easement and histor...

Protectors as Power Players: What the X Trusts Decision Means for US Advisors
05/08/2026

Protectors as Power Players: What the X Trusts Decision Means for US Advisors

On 19 March 2026, the Judicial Committee of the Privy Council handed down its decision in A and 6 others v C and 13 others UKPC 11, the late...

Borrowed From the IRS: How Payroll Tax Evasion Turns Small Shortcuts Into Big Trouble
05/08/2026

Borrowed From the IRS: How Payroll Tax Evasion Turns Small Shortcuts Into Big Trouble

Payroll tax evasion is quietly becoming one of the riskiest “shortcuts” a business can take, and recent cases show that the government is re...

When Offshore Trusts Meet IRS Collection: United States v. Kroner
04/29/2026

When Offshore Trusts Meet IRS Collection: United States v. Kroner

The IRS’s long‑running battle with Florida taxpayer Burt Kroner shows how far the government will go to reach assets held in offshore trusts...

New 1% IRS Tax on Remittance Transfers: What Senders and Providers Need to Know
04/29/2026

New 1% IRS Tax on Remittance Transfers: What Senders and Providers Need to Know

On April 13, 2026, the IRS and Treasury released proposed regulations under new Internal Revenue Code section 4475, explaining how a new 1% ...

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