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Proposed Regulations for Partnership Interests Permits Estate, Income and Charitable Planning Opportunity
The new Administration has areas of taxation estate planning and philanthropy on the front burner. No one is sure what will be happening with the minority discounts regulations of § 2504 in turmoil and proposed guidance of the modification of charities partnership interest and unrelated business taxable income (UBTI). By integrating a number of tried and tested tools, we may create a platform for substantial savings.
The idea is the Charitable Family Limited Partnership (CFLP), which is a charitable giving vehicle that provides a substantial gift to charity, produces income tax savings for the donor, transfers significant wealth to the donor's descendants and allows a means for the donor's family to retain control over the transferred assets.
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The DOJ's Corporate Enforcement Policy: One Year Later
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
Use of Deferred Prosecution Agreements In White Collar Investigations
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
The DOJ's New Parameters for Evaluating Corporate Compliance Programs
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
CLE Shouldn't Be the Only Mandatory Training for Attorneys
Each stage of an attorney's career offers opportunities for a curriculum that addresses both the individual's and the firm's need to drive success.
Discovery of Claim Construction and Infringement Analysis May be Compelled Prior to a Markman Hearing
A defendant in a patent infringement suit may, during discovery and prior to a <i>Markman</i> hearing, compel the plaintiff to produce claim charts, claim constructions, and element-by-element infringement analyses.