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International
Tax
Commentaries |

U.S. Portfolio Investments
by
Ronald A. Marini
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Attorney
Profiles.
Ronald
A. Marini,
J.D., LLM in Taxation.
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Mr.
Marini concentrates his practice in the areas of International and
Tax Law, Asset Protection, Estate Planning, and Representation before
the IRS and other Tax Authorities. During his more
than 20-year career in international tax law, he has represented a broad
spectrum of international and domestic clients including Fortune 500
companies, major non-U.S. businesses and high net worth individuals Mr.
Marini has authored numerous articles and several books including:
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“U.S.
Portfolio Investments,” CCH International Tax Commentaries.
Mr. Marini has also lectured on the following subjects: “Income Tax Litigation, Florida Institute of
Certified Public Accountants, “Expand Your Market:
International Real Estate, Miami Board Of Realtors, “Advanced
International Tax Seminar for Partners and Managers, Arthur
Andersen & Co. and “Foreign Investment in U.S. Real
Estate,” The World Trade Center Institute, New York.
Mr. Marini is admitted
to practice before the U.S. Tax Court.
He is also a member of the Florida Bar, member of A.I.T.C.
(Association of International Tax Consultants), and the Florida
International Tax Group, which is an invitational only group, of the
best International Tax Advisors in the State of Florida.
Mr. Marini is able to transact business in English and Italian.
Prior
to forming Marini & Associates, P.A.
Mr. Marini was with Arthur
Andersen & Co. (AA), in Miami, Florida and was listed as a
firm-wide International Tax Specialist in AA’s Worldwide
Directory. Mr. Marini was 1
of 15 tax professionals, with whom AA recommended consulting with when
advising clients on international tax issues. In addition AA considered
Mr. Marini as an International Shipping Specialist.
Education.
Bachelor of Science in Accounting, Villanova University, Villanova,
Pennsylvania, 1979 Magna Cum Laude; Juris Doctor, Villanova University,
School of Law, Villanova, Pennsylvania, 1982; and LLM (Taxation),
University of Miami School of Law, Coral Gables, Florida, 1985.
Robert
S. Blumenfeld, Of
Counsel, J.D.
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Mr.
Blumenfeld concentrates his practice in the areas of International Tax and
Estate Planning, Probate Law, and Representation of
Resident and Non-Resident Aliens before the IRS.
Prior
to joining Marini & Associates, P.A.,
he spent 32 years as the Senior
Attorney with the Internal Revenue Service (IRS), Office of
Deputy Commissioner, International. While with the
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IRS, he examined
approximately 2,000 Estate Tax Returns and litigated various
international and tax issues associated with these returns.
As a
result of his experience, he has extensive knowledge of the issues
associated with and the preparation of U.S. Estate Tax Returns for Resident
and Non-Resident Aliens, Gift
Tax Returns, Form 706QDT and Qualified Domestic Trusts.
Mr. Blumenfeld is admitted
to practice before the U.S. Tax Court. He is also a member of the
Ohio Bar and he is a member of the Florida
International Tax Group, which is an invitational only group, of the
best International Tax Advisors in the State of Florida.
Harleston
R.
Wood, Of
Counsel, Estate Planning.
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Mr. Wood’s area of specialization is Estate Planning and Probate
Litigation. ESTATE PLANNING
Including income tax planning, asset protection strategies,
succession planning for closely held businesses, estate liquidity
analysis to determine need for different classes of assets, purchase
of life insurance to pay estate taxes or provide ready cash for
surviving spouse, Family
Limited Partnerships, sales to Defective Grantor Trusts, Irrevocable
Life Insurance
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Trusts, Irrevocable Qualified Subchapter S Trusts,
and Direct Skip Generation Skipping Trusts, Special Needs Trusts,
Qualified Personal Residence Trusts, Private Foundations, Operating
Foundations, Museums, etc.
PROBATE
Filing probate administration papers with court;
prepare, review and file Form 706 Estate Tax Return, represent
client in IRS audit of such returns, advise client and fiduciary on
income and estate tax and asset disposition issues of estates.
ARTICLES &
SPEECHES: “Elective Spousal Share,” Estate Tax Planning Advisor,
February 2002; Speech to Miami Beach Estate Planning Attorneys
“Estate Tax Planning With the 2001 Tax Law Changes,” July 2001;
Speech to Gold Coast Accountants Chapter concerning estate tax
planning, October 2000.
Education. Juris Doctorate,
University of Miami, 1979. Master of Business Administration,
Wharton School
of Business and Finance, 1975. Bachelor
of Arts in Economics, University of Pennsylvania, 1967.
Prior to joining
Marini & Associates, P.A.
Mr.
Wood practiced law at Shutts & Bowen, Miami, Florida; BDO
Seidman & Seidman, Miami, Florida; Touche Ross & Co, Miami,
Florida.
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Gary
Pollack, Of
Counsel, J.D.
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Mr.
Pollack’s areas of expertise is complex commercial and contractual
litigation, securities arbitration and fraud. He
is a frequent lecturer, and he is a member of the Federal Trial Bar, Bankruptcy
Bar, National Association of Criminal Defense Lawyers and Commercial Law League.
He is certified as an arbitrator, by the State of
Florida and the National Association of Security Dealers.
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William
McBrayer
Wood, Of
Counsel, LLM
in Estate Planning.
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Mr. Wood’s area of
specialization is Estate Planning and Probate Litigation.
Mr. Wood earned his LLM in Estate Planning, was a capital partner in
the Miami law firm, Shutts & Bowen and is now in an interstate practice in
Florida, South Carolina and the District of Columbia.
He teaches Trial Advocacy at the National Institute of Trial Advocacy
(NITA) in New York and previously was
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a law
professor of Wills & Trusts and Trial Advocacy.
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Jon
C. Hall, J.D.
Mr. Hall is a member of the
Illinois, Indiana and Florida bars and has been associated with this firm
since 1993. His area of
specialization is real estate closings and documentation.
Mr. Hall is a recognized expert in the field of Real Estate (1980
recipient of the Brown L. Whatley Award), a published author in this field
and a frequent speaker concerning Real Estate. Mr. Hall is also the owner of
First Florida Title Services, Inc. First Florida provides the firm with a
differential advantage in being able to expedite real estate closings.
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