PrivateLetter Ruling 201228012 - The IRS issued a private letter ruling allowing a father to transfer his corporate business to his two children through the use of gifts and stock redemption. This transaction results in favorable tax consequences to the father, his children and the corporation. The facts of this ruling are: A father owns all…
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About: Ronald Marini
Recent Posts by Ronald Marini
Tax Developments in the Second Quarter of 2012
This letter highlights some of the more important tax developments that have come out during the second three months of 2012. Most are documents from the Internal Revenue Service, but some are important cases and legislative changes you might want to be aware of for you or your business. Individual Mandate to Buy Health Insurance:…
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Capital Gains Taxes Are Going Up
The top tax rate on long-term capital gains is currently 15%. That’s why Mitt Romney is spending so much time talking about his tax returns. That revelation has set off a familiar debate about whether that low rate is appropriate. Often overlooked in these discussions, however, is the fact that the days of the 15%…
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Treasury Releases Model Intergovernmental Agreement for Implementing the FATCA
WASHINGTON – The U.S. Department of the Treasury today published a model intergovernmental agreement (model agreement) to implement the information reporting and withholding tax provisions commonly known as the Foreign Account Tax Compliance Act (FATCA). Enacted by Congress in 2010, these provisions target non-compliance by U.S. taxpayers using foreign accountsThe agreement was developed in consultation…
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