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Recent Posts by Ronald Marini

Fifth Amendment Privilege Does Not Apply to Swiss Banking Records

M.H. v. U.S. (In re: Grand Jury Investigation M.H.), (9th Cir. 8/19/11):  Facts: Taxpayer (T) is the target of a grand jury investigation seeking to determine whether he used secret Swiss bank accounts to evade paying federal taxes. Records were sought as part of the grand jury's investigation. Under its deferred prosecution agreement with the…
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FLORIDA 2011 PROBATE & TRUST CHANGES

     On April 14, 2011 and April 29, 2011, the Florida legislature enacted several significant changes to the probate and trust code (hereinafter referred to as “legislation”). The bill was signed by the Governor on June 21, 2011. Some of the key sections of the legislation became effective on July 1, 2011 and others will…
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U.S. readies papers v. Swiss banks on tax evasion

Sat Sep 10, 2011 12:50am BST (Reuters) - The United States is drafting legal documents that seek to force nearly a dozen Swiss banks and international banks with Swiss branches to disclose the identities of American clients evading billions of dollars in taxes, sources briefed on the matter said. The drafting of the documents --…
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OVDI Ends Today – The Going Gets Tougher!

/* extlib: _anetfollow */ LI.i18n.register( 'followSingular', '{0} follower' ); LI.i18n.register( 'followPlural', '{0} followers' ); LI.Controls.addControl('control-8', 'AnetFollow', { countNode: 'count-58738015' }); With 7 million Americans living overseas - but just 462,340 filing US Tax Returns every year - the IRS is certain to get tougher after today. Filing any “delinquent” returns in the next few weeks…
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