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Recent Posts by Ronald Marini

Administration's Proposed New Tax on Family Trusts.

Each 90 years, trusts will pay the new 45 percent estate tax.  The tax is on the value of its assets.   Trust funded before this law is passed are exempt. You need to move fast. The Administration hasissued a 200-page report with new tax laws including this law. While many new loopholes and tax breaks are…
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Treasury, IRS Issue Proposed Regulations for FATCA Implementation

WASHINGTON — The Treasury Department and the Internal Revenue Service today issued proposed regulations for the next major phase of implementing the Foreign Account Tax Compliance Act (FATCA). Enacted by Congress in 2010, the law targets non-compliance by U.S. taxpayers using foreign accounts. The regulations lay out a step-by-step process for U.S. account identification, information…
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The Tresury and European Governments Agree to Pursue Framework for Implementing FATCA

The Treasury Department has reached an agreement with the governments of France, Germany, Italy, Spain, and the United Kingdom for designing a framework to implement the information reporting and withholding provisions by foreign financial institutions under the Foreign Account Tax Compliance Act (FATCA). According to Treasury's news release, the governments expressed their “mutual intent to…
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“RELIANCE” DEFENSE WAIVES WORK PRODUCT & ATTORNEY-CLIENT PRIVILEGE PROTECTION

In litigation, the work-product doctrine and the attorney-client privilege protect materials and communications from discovery by an adversary in litigation. The work-product doctrine excludes from discovery materials prepared in anticipation of litigation because discovery of such materials would hamper the orderly prosecution and defense of legal claims in adversary proceedings. The attorney-client privilege extends to…
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