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March 25, 2008
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Lucy Lee
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"The Free State Accountant" (Journal of the Maryland Society of Accountants)
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April-May 2008
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Scott Michel
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February 2008
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Scott Michel
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November 1, 2007
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Stafford Smiley, Brian Lynn
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September 2007
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Scott Michel
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ALI-ABA Estate Planning Course Materials Journal, April 2007
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M. Ruth Madrigal
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Richard Skillman, Seth Green, James Mastracchio, Kevin Thorn
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Tax Notes, March 5, 2007
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Brian Lynn
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Cono Namorato, Patricia Lewis
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Taxation of Exempts, January/February 2007
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M. Ruth Madrigal
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Tax Analysts, October 30, 2006
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Marcus Owens, Natalie Fay Green
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Caplin & Drysdale Tax Alert, October 2006
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Patricia Lewis, Elizabeth Peters, Christopher Rizek, Rebecca Rosenberg, Kevin Thorn
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Andrews Litigation Reporter: White Collar Crime, September 2006
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Scott Michel
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| This article discusses a 2006 decision by the U. S. Court of Appeals for the District of Columbia interpreting the act-of-production doctrine under the Fifth Amendment privilege and, in particular, extending the scope of protection afforded by a grant of act-of-production immunity in connection with a witness's production of documents. |
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Caplin & Drysdale Tax Alert, May 2006
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Robert Green
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| In this edition of TaxAlert, Mr. Green shares his finely honed insights into the vital need for global strategies in resolving tax disputes. |
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Practical US/Domestic Tax Strategies, May 2006
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Neal Kochman
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Journal Of Tax Practice and Procedure, April/May 2006
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Kevin Thorn
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| This article provides a rare look inside the IRS's Office of Professional Responsibility, outlines some of the more important issues that practitioners should pay particular attention to, and discusses the Office's expanded jurisdiction and new sanctions under the Jobs Act. |
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The Tax Executive, January/February 2006
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Scott Michel, Kevin Thorn
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| This article addresses the recent trend toward the use of "deferred prosecution agreements" in disposing of corporate criminal investigations, describes the concept of deferred prosecution and how it has been applied in the tax context, and examines the implications for corporate tax executives and their departments. |
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Caplin & Drysdale Tax Alert, January 2006
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Neal Kochman, Christopher Rizek, Joseph Birkenstock, Kevin Thorn
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Tax Management International Journal, December 9, 2005
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Neal Kochman
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Tax Notes, October 3, 2005
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Brian Lynn
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Re:Cap, August 2005
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International Law Office, August 2005
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Richard Timbie, Scott Michel
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| This article notes the increasing IRS enforcement scrutiny of US taxpayers with foreign accounts or foreign source income, and recommends that non-US tax practitioners review their clients' affairs and evaluate whether a "voluntary disclosure" to US tax authorities might be appropriate. |
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Taxes - The Tax Magazine, July 2005
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Brian Lynn
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Caplin & Drysdale Tax Alert, June 2005
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Neal Kochman, H. Rosenbloom, Patricia Lewis
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| In this edition of TaxAlert, Ms. Lewis discusses the surprising international implications of the new deferred compensation law, Mr. Kochman discusses new developments on contingent attorney fees, and Mr. Rosenbloom discusses how european court tax decisions could impact U.S. taxpayers' foreign tax credits. |
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Re:Cap, May 2005
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Re:Cap, April 2005
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Re:Cap, March 2005
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Re:Cap, February 2005
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Caplin & Drysdale Tax Alert, February 2005
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Seth Green, Marcus Owens, Michael Pfeifer
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| In this edition of TaxAlert, Mr. Green discusses how the IRS provides guidance on repatriations under the new Section 965, Mr. Owens discusses IRS audit plans for private foundations and publicly-supported charities, and Mr. Pfiefer discusses the changes to individual expatriation rules. |
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Exempt Organizations Tax Review, February 2005
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Michael Durham
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| This article discusses the role of the International NGO Community relief efforts and what preventative measures will be made in the future to alleviate the harmful effects of future disasters. |
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The Exempt Organization Tax Review, January 2005
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| This article originally appeared in the Exempt Organization Tax Review, a publication of Tax Analysts. |
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Re:Cap, January 2005
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Corporate Business Taxation Monthly, January 2005
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James Salles
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Business Crime Bulletin, December 2004
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Scott Michel
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| Mr. Michel’s article addresses areas of potential interaction between the IRS Office of Professional Responsibility (OPR), which is charged with regulating professionals who practice before the IRS (mostly lawyers and accountants), and the criminal tax investigative process. |
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White Collar Crime Reporter, December 2004
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Scott Michel
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| Mr. Michel's article addresses one of the more complex and intriguing issues that arise in a criminal tax investigation, the annual requirement that every U.S. taxpayer file a timely, accurate and complete tax return, and the implications of this requirement for the target of the investigation. |
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Corporate Business Taxation Monthly, December 2004
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James Salles
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Re:Cap, December 2004
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Re:Cap, November 2004
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Caplin & Drysdale Tax Alert, November 2004
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Christopher Rizek
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| In this edition of TaxAlert, Ms. Katz summarizes a number of international tax matters, Mr. Doran discusses deferred compensation, and Mr. Rizek discusses tax shelter reform. |
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Re:Cap, October 2004
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Caplin & Drysdale, September 2004 (Published in October 1998)
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Thomas Troyer
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| Handbook on Voter Participation and Education Work for 501(c)(3)Organizations. |
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Re:Cap, September 2004
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Tax Notes, September 22, 2004
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| Another election season is upon us and with it a flurry of information — and misinformation — about what churches and other religious organizations can and cannot do. Fortunately for religious leaders, the law is relatively clear. |
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Corporate Business Taxation Monthly, September 2004
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James Salles
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Tax Notes International, August 9, 2004
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Rebecca Rosenberg
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| New temporary and proposed regulations issued on July 27, 2004, affect the apportionament of charitable deductions between U.S.- and foreign-source income. |
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Corporate Business Taxation Monthly, August 2004
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James Salles
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The Exempt Organization Tax Review, August 2004
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Caplin & Drysdale Tax Alert, July 2004
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Lloyd Mayer, Richard Timbie, Patricia Lewis, Scott Michel
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| In this edition of Tax Alert, Ms. Lewis discusses the first of several important new guidance items expected this year in the transfer pricing arena. Mr. Michel and Mr. Timbie address the IRS devoting substantial resources to investigate individuals who have offshore financial accounts. Mr. Mayer talks about current development for exempt organizations. Mr. Cerny highlights several important events that occurred during his recent trip to Russia where he advised on specific revisions to their nonprofit tax laws. |
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Re:Cap, June 2004
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Taxes - The Tax Magazine, June 2004
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Brian Lynn
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Tax Notes International, May 10, 2004
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H. Rosenbloom
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| Tax Notes International interviews Caplin & Drysdale attorney H. David Rosenbloom as part of its series of interviews with people who have had an impact on international taxation. |
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Re:Cap, April 2004
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Caplin & Drysdale TaxAlert, April 2004
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Christopher Rizek, Daniel Rosenbaum, Kirk Jowers
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| In this edition of TaxAlert, Mr. Rosenbaum discusses Section 6700. Mr. Rizek discusses taxpayers concerns on how to maintain the confidentiality of sensitive information once it is turned over a Congressional committee so that it is not "redisclosed" to other third parties. Mr. Jowers explains the impact of the bipartisan campaign reform act on tax exempt organizations. |
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The Sydney Law Review, March 2004
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H. Rosenbloom
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| This paper examines the U.S. tax treatment of 'related party debt,'especially in transactions involving entities under common control. |
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The Tax Magazine, March 2004
|
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H. Rosenbloom
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Re:Cap, March 2004
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The Exempt Organization Tax Review, February 2004
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Re:Cap, February 2004
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Re:Cap, January 2004
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Tax Notes International, December 15, 2003
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H. Rosenbloom
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Tax Notes International, December 8, 2003
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H. Rosenbloom
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The Tax Executive, November/December 2003
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Patricia Lewis
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| Originally published in the November-December 2003 issue of The Tax Executive. Reprinted with permission by Tax Executives Institute and the authors. |
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The Tax Executive, November/December 2003
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Scott Michel
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| Originally published in the November-December 2003 issue of The Tax Executive. Reprinted with permission by Tax Executives Institute and the authors. |
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Re:Cap, December 2003
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Corporate Business Taxation Monthly, November 2003
|
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James Salles
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| This month's column discusses United States v. Brown, in which the Tenth Circuit upheld the regulations under section 468B(g) concerning "qualified settlement funds. |
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Caplin & Drysdale TaxAlert, November 2003
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Christopher Rizek, Lloyd Mayer, James Salles, Patricia Lewis
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| In this edition of TaxAlert, Caplin & Drysdale lawyers summarize a number of recent Government actions that may have significance for your own work on current tax issues. |
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Re:Cap, November 2003
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Corporate Business Taxation Monthly, October 2003
|
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James Salles
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| The tax accounting column discusses recent administrative guidance, including temporary regulations rewriting the rules for the "nonaccrual experience method" under section 448(d)(5), and the treatment of tax-exempt employers' option plans in the final regulations under section 457. |
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The Exempt Organization Tax Review, October 2003
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| The article discusses the formation, regulation and tax aspects of nongovernmental organizations in the developing nonprofit sector of China. |
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Re:Cap, October 2003
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The Exempt Organization Tax Review, September 2003
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| This first of a two-part article examines the current state of the law of charitable organizations in the Russian Federation. |
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Re:Cap, September 2003
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Corporate Business Taxation Monthly, September 2003
|
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James Salles
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| This month's column discusses the Tax Court's redetermination of swaps' market value in Bank One, and the Eighth Circuit's recent holding that changing a property's MACRS classification is not a change in accounting method. |
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Re:Cap, August 2003
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Corporate Business Taxation Monthly, August 2003
|
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James Salles
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| The tax accounting column discusses the latest proposed regulations on “split-dollar” life insurance arrangements, proposed changes to the “spread periods” for certain accounting method changes, and a new IRS ruling allowing utilities to treat the proceeds of certain fuel surcharges as loans. |
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Committee on Finance, United States Senate, July 15, 2003
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H. Rosenbloom
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| David Rosenbloom expresses his views on "U.S. Tax Policy and Its Effect on the International Competitveness of U.S.-Owned Foreign Operations." His testimony describes a context in which the international tax issues facing the U.S. Senate Committee on Finance might be considered. |
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Corporate Business Taxation Monthly, July 2003
|
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James Salles
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| In part two of the May 2003 column, this month's tax accounting column discusses capitalizing taxpayer’s internal costs (employee labor and overhead) under the case law and the proposed “INDOPCO regulations.” |
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Re:Cap, July 2003
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Legal Times, September 2003
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Scott Michel
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| Buildable Hours works with Habitat for Humanity to give families a new home. |
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Re:Cap, June 2003
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Caplin & Drysdale Memorandum, May 7, 2003
|
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Christopher Rizek
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Caplin & Drysdale Memorandum, May 5, 2003
|
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Lloyd Mayer
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| This memorandum summarizes the campaign finance reform's recent court decision and the effect the decision has on the provisions that most directly impact tax-exempt organizations. |
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Taxation of Exempts, May/June 2003
|
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Lloyd Mayer
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Re:Cap, May 2003
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Corporate Business Taxation Monthly, May 2003
|
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James Salles
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| This column discusses capitalization of taxpayers' "internal" costs (employee labor and overhead) in the case law and under the proposed "INDOPCO regulations." |
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Re:Cap, April 2003
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Corporate Business Taxation Monthly, April 2003
|
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James Salles
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| This column discusses the Fifth Circuit's recent decision in Commissioner v. Brookshire Brothers Holding, Inc., in which the Fifth Circuit held that a change in property's classification under MACRS was not a change in accounting method, and also that the Service could not inquire whether a method change in now-barred year was authorized. |
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Caplin & Drysdale TaxAlert, April 2003
|
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Christopher Rizek, Daniel Rosenbaum, Seth Green, Patricia Lewis, Richard Skillman
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| In this edition of the TaxAlert, Caplin & Drysdale lawyers summarize a number of recent Government actions that may have significance for your own work on current tax issues. |
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Re:Cap, March 2003
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Corporate Business Taxation Monthly, March 2003
|
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James Salles
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| This column discusses Revenue Ruling 2003-3, concerning the accrual of tax refunds; Revenue Ruling 2003-10, dealing with receivables subject to customer disputes; new rulings on captive insurance issues; and new guidance under the "nonaccrual experience method" of section 448(d)(5). |
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Corporate Business Taxation Monthly, February 2003
|
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James Salles
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| This column discusses Notice 2002-79, proposing a new procedure to replace Revenue Procedure 71-21, which allows deferral of advance payments for services. |
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Re:Cap, February 2003
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Caplin & Drysdale Tax Advice, January 24, 2003
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Washington Legal Foundation (www.wlf.org), January 2003
|
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Lloyd Mayer
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Re:Cap, January 2003
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Corporate Business Taxation Monthly, December 2002
|
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James Salles
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| The column discusses Revenue Ruling 2002-71, which applies the "hedge timing" rules under Regs. section 1.446-4; the "track maintenance allowance system" for railroads under Revenue Procedure 2002-65; and the Tax Court's decision in Tampa Bay Devil Rays allowing deferral of ticket revenue. |
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Re:Cap, December 2002
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Tax Management International Journal, November 8, 2002
|
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Neal Kochman, Patricia Lewis
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| The article discusses the controversy surrounding financial accounting of compensatory stock options. (The article was reproduced with permission. All rights reserved.) |
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Corporate Business Taxation Monthly, November 2002
|
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James Salles
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| The column is the second of a two-part discussion of the new regulations under sections 441 and 442, and Revenue Procedures 2002-37, 2002-38, and 2002-39, concerning taxpayers' applications for permission to change taxable years. (Please see October 2002 column for part one.) |
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Re:Cap, November 2002
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Taxation of Exempts, November/December 2002
|
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Lloyd Mayer
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Corporate Business Taxation Monthly, October 2002
|
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James Salles
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| The column is the first of a two-part discussion of the new regulations under sections 441 and 442, and Revenue Procedures 2002-37, 2002-38, and 2002-39, concerning taxpayers' applications for permission to change taxable years. (Please see November 2002 column for part two.) |
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Re:Cap, October 2002
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Corporate Business Taxation Monthly, September 2002
|
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James Salles
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| The column discusses proposed amendments to the section 457 regulations that would currently tax compensatory options at grant, a new revenue procedure offering a "safe harbor" for utility financing orders, and tax accounting aspects of the IRS' 2002-03 business plan. |
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Re:Cap, September 2002
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The Tax Executive, July-August 2002
|
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Patricia Lewis
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