Marini & Associates PA

10/16/2026

From GILTI to NCTI: The 2026 Tax Changes Every U.S. Owner of a Foreign Business Should Know

U.S. Taxation of Foreign Business Income For purposes of this discussion, a “U.S. person” generally includes a U.S. citizen, lawful permanen...

10/14/2026

From GILTI to NCTI: The 2026 Tax Changes Every U.S. Owner of a Foreign Business Should Know

10/09/2026

https://www.thetaxtimes.com/2026/10/mistake-or-fraud-what-gaos-new-304.html

On September 25, 2026, the U.S. Government Accountability Office released a report titled " Tax Fraud: The Federal Government Loses an Estim...

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...

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. ...

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...

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...

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 ...

09/10/2026

https://www.thetaxtimes.com/2026/09/the-irss-inflation-reduction-act.html

The IRS’s Inflation Reduction Act Spending Through March 31, 2026

On September 1, 2026, the Treasury Inspector General for Tax Administration (TIGTA) released its fourth periodic snapshot of how the IRS has...

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...