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Allison, Mark D.
Armitage, J. Clark
Barnes, Peter A.
Barzell, Dustin J.
Biss, Meghan R.
Black, Jonathan R.
Brenner, Jonathan S.
Burmester, Kirsten
Caplin (1916 - 2019), Mortimer M.
Carney, Leila D.
Carney, Robert T.
Child, Josiah
Cox , Katy
Davis, Kevin M.
Dlott , Moshe A.
Drysdale (1924 - 2018), Douglas D.
Egan, Alison F.
Eisenstat, Benjamin Z.
Elber, Niles A.
Esman, Aaron M.
Fournier, William D.
Goon , Michael
Hannes, Steven P.
Jaramillo, Victor A.
Kaufman, Beth Shapiro
Kelleher, Leslie M.
Klimon, William M.
Kochman, Neal M.
Koski, Jeanna Rickards
Laughlin, Felix B.
Leon, Amanda M.
Lewis, Patricia Gimbel
Liesemer, Jeffrey A.
Maclay, Kevin C.
Marshall, Olivia N.
Matthews, Mark E.
McMillan, Ann C.
Mehany, Dianne C.
Michel, Scott D.
Miller, Nathaniel R.
Morgan, Bryson B.
Namorato, Cono R.
O'Brien, Anne J.
O'Connor, George M.
Partain, Rachel L.
Phillips, Todd E.
Polk, Shauna
Potter, Trevor
Racicot, Sarah J.
Reed, Amanda
Rizek, Christopher S.
Rosenbaum, Daniel B.
Rosenbloom, H. David
Ruchelman, Charles M.
Sackett, Andrew J.
Salles, James E.
Sanderson, Matthew T.
Schick, Sharon H.
Scott, Leighanne
Sharkey, Ross R.
Skillman, Richard W.
Slocombe, Walter B.
Smiley, Stafford
Stevens, Elizabeth J.
Varley, Douglas N.
Want, Sharon P.
Wehner, James P.
Wernke, Megan E.
Yoon, Sae Jin
Ziering, Zhanna A.
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Business, Investment & Transactional Tax Alert
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Alerts
Private Client Alert
UPDATE: Gift Tax Return Due Date Now July 15, 2020
March 27, 2020
Private Client Alert
Estate and Gift Tax Return Due Dates Not Postponed
March 27, 2020
Tax Alert
CARES Act Offers Income Tax Relief for Business
March 27, 2020
State and Local Tax Alert
Maryland General Assembly Votes to Adopt Digital Advertising Gross Revenue Tax & Expand Sales Tax to Digital Products
March 20, 2020
Political Law Alert
After Multiple Lawsuits, New Jersey Nonprofit Disclosure Law Permanently Enjoined
March 18, 2020
International Tax Alert
The OECD Unified Approach Marches (Stumbles?) Forward
February 11, 2020
Private Client Alert
Congress Takes the Stretch Out of IRAs (and Other Retirement Assets)
January 6, 2020
Business, Investment & Transactional Tax Alert
Updated Partnership Reporting Requirements for 2019
December 13, 2019
International Tax Alert
OECD Announces a Public Consultation for Global Minimum Tax Rules
November 25, 2019
International Tax Alert
An OECD "Unified Approach" to Addressing the Challenges of the Digital Economy
November 4, 2019
Tax Alert
New Cryptocurrency Guidance
October 22, 2019
Political Law Alert
New Jersey Nonprofit Disclosure Law Temporarily Blocked By Federal Judge
October 3, 2019
Political Law Alert
Federal Judge Strikes Down New York Lobbying and Issue Advocacy Donor Disclosure Requirements
October 3, 2019
Exempt Organizations Alert
Update on Nonprofit Donor Disclosure Requirements: IRS Tries Again
September 10, 2019
Political Law Alert
New Jersey Nonprofit Donor Disclosure Law Faces Lawsuit
August 5, 2019
Exempt Organizations Alert
Update on Nonprofit Donor Disclosure Requirements
August 1, 2019
Political Law Alert
Chicago Passes New Ordinance Repealing Nonprofit Exemption from Lobbying Rules
July 30, 2019
Tax Alert
Cryptocurrency Criminal Tax Cases Coming Soon
July 23, 2019
International Tax Alert
The Proposed GILTI High Tax Exclusion
July 1, 2019
Private Client Alert
Supreme Court Rules Against North Carolina in
Kaestner
On State Income Taxation of Trusts: What Does This Mean for the District of Columbia, Virginia, and Maryland?
June 26, 2019
Tax Alert
Tax Problems Loom in the College Admissions Scandal
March 18, 2019
Political Law Alert
DOJ National Security Division Announces Significant Appointment and Shift on FARA Enforcement
March 7, 2019
Political Law Alert
Governor Inslee's Presidential Campaign Triggers New Risks for Investment Advisers
March 6, 2019
Political Law Alert
FEC Updates Contribution Limits for 2019-2020
February 7, 2019
Exempt Organizations Alert
What You Need to Know About the New Tax on "Excess" Nonprofit Compensation
January 11, 2019
Tax Alert
The New Voluntary Disclosure Practice: A Fair Compromise?
December 3, 2018
Private Client Alert
UPDATED: Year-End Charitable Giving Ideas: IRA Rollovers and "Bunching" Charitable Deductions
November 28, 2018
Business, Investment & Transactional Tax Alert
Proposed Regulations Under Section 956
November 6, 2018
Tax Alert
Year-End Updates on Partnership Representatives
November 6, 2018
Business, Investment & Transactional Tax Alert
When Opportunity Knocks: Qualified Opportunity Zone Proposed Regulations Released
October 22, 2018
Political Law Alert
New York's Comprehensive Lobbying Rules Set to Take Effect January 1, 2019
September 28, 2018
Political Law Alert
U.S. Supreme Court Denies Request for Stay of Ruling Requiring Nonprofit Donor Disclosure
September 19, 2018
Exempt Organizations Alert
IRS Issues Guidance on Calculating Unrelated Business Income Tax
August 23, 2018
Political Law Alert
Federal District Court Vacates FEC Independent Expenditure Donor Disclosure Rule; Appeal Likely
August 9, 2018
Exempt Organizations Alert
IRS Donor Disclosure Requirements Eliminated for Most Nonprofit Organizations
July 17, 2018
Political Law Alert
Justice Department Releases Foreign Agent Advisory Letters
June 11, 2018
Tax Alert
IRS Adds Foreign Trust Information Reporting to Compliance Campaign Program
June 1, 2018
Political Law Alert
An Overview of Political Advertising Policies for Google, Twitter, and Snapchat
May 21, 2018
Political Law Alert
An Overview of Facebook's Election-Related Disclosure Program for Advertisers
May 3, 2018
Tax Alert
IRS's Offshore Voluntary Disclosure Program Ending: Impact on U.S. Taxpayers
March 14, 2018
Exempt Organizations Alert
IRS Guidance Removes Obstacle to Restructuring Tax-Exempt Organizations
March 8, 2018
Tax Alert
IRS to Revoke Passports for Seriously Delinquent Tax Debts Starting February 2018
February 12, 2018
Exempt Organizations Alert
New IRS Procedures Will Impact Nonprofits
January 25, 2018
Private Client Alert
2018 Ushers In New Estate Planning Opportunities and Pitfalls
January 18, 2018
Tax Alert
New Partnership Audit Rules Go Live
January 9, 2018
Tax Alert
Tax Reform May Make Payment of Nonbusiness Tax Advice Fees Non-Deductible
December 12, 2017
Tax Alert
Possible Tax Fallout for Student and Professional Athletes from NCAA-Related Investigations
November 9, 2017
Tax Alert
Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets
November 6, 2017
International Tax Alert
Different Viewpoint Not a Misrepresentation: Tax Court Holds IRS Abused Its Discretion in Cancelling Eaton's APAs
August 24, 2017
Employee Benefits Alert
Court Rules Unanimously in Church Pension Plan Cases
June 7, 2017
Tax Alert
Captive Insurance Industry Should Be Aware of State Reporting Obligations for Transactions of Interest
February 10, 2017
Tax Alert
IRS Launches 13 Issue-Based Corporate Compliance Campaigns
February 3, 2017
Political Law Alert
FEC Updates Contribution Limits for 2017-2018
February 2, 2017
Political Law Alert
President Trump Issues Executive Order on Ethics
February 1, 2017
Political Law Alert
SEC Fines 10 Investment Advisers for Pay-to-Play Violations
January 27, 2017
Tax Alert
Syndicated Conservation Easement Transactions Identified as New "Listed Transactions"
January 3, 2017
Employee Benefits Alert
Qualified Retirement Plans in 2017 and Beyond: Resources & Considerations for Employers
December 29, 2016 - UPDATED March 8, 2017
International Tax Alert
Treasury Issues Final Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership
December 19, 2016
Business, Investment & Transactional Tax Alert
Tax Plans Compared (December 2016) Corporate Tax
December 16, 2016
Tax Alert
Congress Looks to Fix New Partnership Audit Rules
December 14, 2016
Private Client Alert
Possible Repeal of the Estate Tax in 2017
December 5, 2016
Private Client Alert
Tax Plans Compared (December 2016) Individual Income Tax
December 5, 2016
Tax Alert
Voluntary Disclosure Window Closing on Bitcoin Users
December 2, 2016
Political Law Alert
Office of Government Ethics Revises Executive Branch Gift Rules
November 18, 2016
Tax Alert
Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations
November 3, 2016
Business, Investment & Transactional Tax Alert
New Regulations Change Allocation of Partnership Liabilities
October 24, 2016
Tax Alert
IRS Issues First Partnership Audit Regulations
August 8, 2016
Employee Benefits Alert
The Proposed 457 Regulations: Bona Fide Severance Pay Plan and Substantial Risk of Forfeiture
July 11, 2016
Political Law Alert
New York Passes New Legislation Affecting Political Activity at the Local and State Level
July 5, 2016
Employee Benefits Alert
Recent Litigation Addresses the Benefit Plans of Religious Organizations
June 13, 2016
Tax Alert
The Panama Papers and the U.S. Response: New Risks for Financial Institutions, Clients and Advisors
May 18, 2016
Tax Alert
IRS to Hire 700 for Civil and Criminal Tax Enforcement
May 5, 2016
Political Law Alert
IRS Rules Against Deductibility of Charitable Donations Made as Part of PAC Matching Program
April 27, 2016
Employee Benefits Alert
The New Fiduciary Rules: Considerations for Employers
April 12, 2016
Tax Alert
Treasury Announces Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership
April 5, 2016
Political Law Alert
California Limits "Ride-Along" Lobbying Exception to Employees Who are Subject Matter Experts
March 24, 2016
Tax Alert
IRS Seeks Comments to Promulgate Regulations for New Tax Examination and Collection Regime for Partnerships and LLCs
March 18, 2016
Tax Alert
IRS/DOJ Summons Seeks to Break Singapore Bank Secrecy on Non-Resident's Account
March 7, 2016
Political Law Alert
California Enhances Lobbying Disclosure Requirements for Lobbyist Employers and "$5,000 Filers"
January 25, 2016
Private Client Alert
2016 Federal and State Estate Gift Tax Exemptions for D.C., Maryland, and Virginia
December 28, 2015
International Tax Alert
Is It the Real Thing? The IRS Makes $9+ Billion of Transfer Pricing Adjustments Against The Coca-Cola Company
December 23, 2015
Private Client Alert
Charitable IRA Rollovers Made Permanent In Recent Extenders Bill
December 21, 2015
Tax Alert
Congress Enacts Entirely New Tax Examination and Collection Regime for Partnerships
December 10, 2015
Employee Benefits Alert
DOL Releases 2015 Form 5500 Including New IRS Compliance Questions
December 9, 2015 - UPDATED February 23, 2016
Tax Alert
U.S. Passports in Jeopardy for Taxpayers Owing the IRS
December 9, 2015
Political Law Alert
Political Intelligence Firm Fined $375,000, Underscoring Need to Tailor Insider Trading Policies to Interactions with Government
December 1, 2015
Private Client Alert
Steps Foreign Persons Can Take to Avoid Unnecessary U.S. Estate Tax
November 9, 2015
International Tax Alert
The Final OECD BEPS Tome Has Arrived
October 8, 2015
Exempt Organizations Alert
IRS Releases Final Foreign Grantmaking Regulations
September 29, 2015
International Tax Alert
Strategic Resets Under the New MAP and APA Revenue Procedures
September 23, 2015
Employee Benefits Alert
IRS Releases Guidance on Voluntary 2015 PPACA Information Reporting
September 1, 2015
Political Law Alert
Carmen Group's $125,000 Penalty Latest in Increased Lobbying Disclosure Act Enforcement
August 31, 2015
International Tax Alert
Transfer Pricing Audits: Flipping the Tested Party
August 13, 2015
Tax Alert
New Law Changes FBAR Filing Deadline
August 10, 2015
Employee Benefits Alert
'Steering' the Cadillac Tax II: An Additional Opportunity for Employers and Other Stakeholders
August 5, 2015
International Tax Alert
IRS Releases Guidelines for Examining CFC Transactions
July 29, 2015
Employee Benefits Alert
Supreme Court Ruling on Same-Sex Marriage Impacts Employee Benefit Plan Administration
July 1, 2015
International Tax Alert
Treasury Proposes Significant Changes to U.S. Model Tax Treaty
May 26, 2015
Employee Benefits Alert
Investment Advice and ERISA Fiduciary Responsibility
May 26, 2015
Private Client Alert
Maryland Taxpayers Win Income Tax Case in Supreme Court
May 20, 2015
Employee Benefits Alert
'Steering' the Cadillac Tax: An Opportunity for Employers and Other Stakeholders
March 4, 2015
Employee Benefits Alert
IRS Releases Additional Guidance on Reporting Health Coverage Information
February 25, 2015
Tax Alert
Abusive Small Captive Insurance Companies Added to IRS "Dirty Dozen Tax Scams"
February 13, 2015
Political Law Alert
FEC Updates Contribution Limits for 2015-2016
February 3, 2015
Business, Investment & Transactional Tax Alert
NYC Proposed Tax Code Changes Would Affect Businesses Large and Small
January 13, 2015
Political Law Alert
Increased Campaign Contribution Limits in 2015 Omnibus Appropriations Act
December 17, 2014
Tax Alert
Switzerland Narrows Advance Notice to Account Holders of Treaty Requests: Americans with Unreported Accounts Impacted
December 16, 2014
Political Law Alert
Political Activities and the Law: Mitigating Risks for Corporations and Nonprofits
October 15, 2014
Political Law Alert
Caplin & Drysdale Comments on Municipal Securities Rulemaking Board's Proposed Changes to "Pay-to-Play" Restriction
October 1, 2014
International Tax Alert
OECD Releases Finalized Proposals on Key Tax Base Erosion Concerns
September 23, 2014
Employee Benefits Alert
IRS Releases Draft Instructions for Reporting Health Coverage Information
September 12, 2014
Exempt Organizations Alert
Letter to DOJ Confirms IRS Intent to Resume Church Tax Inquiries
August 7, 2014
Tax Alert
IRS Issues Final Regulations on Material Advisor Penalties
August 4, 2014
Employee Benefits Alert
Recent IRS Activity Focuses on Nonqualified Deferred Compensation Plans
July 7, 2014
Political Law Alert
SEC Issues "Pay-to-Play" Penalty to Investment Adviser
June 26, 2014
Tax Alert
IRS Modifies Offshore Voluntary Disclosure Program and Streamlined Filing Compliance Procedures
June 23, 2014
Private Client Alert
Maryland Estate Tax Exemption Set to Rise
May 16, 2014
Employee Benefits Alert
IRS Issues Important Guidance for Employers on Application of
U.S. v. Windsor
to Qualified Retirement Plans
April 10, 2014 - UPDATED May 20, 2014
Employee Benefits Alert
IRS Modifies Program for Pre-Approval of 403(b) Plan Documents
April 8, 2014
Political Law Alert
U.S. Supreme Court Releases Opinion in
McCutcheon v. Federal Election Commission
April 2, 2014
International Tax Alert
Remain Vigilant on Indian Permanent Establishments, Even After the Favorable e-Funds Decision
March 27, 2014
Employee Benefits Alert
Final IRS Regulations on Information Reporting Under PPACA
March 24, 2014
International Tax Alert
Bold Shift in IRS Approach to Transfer Pricing Controversies
February 27, 2014
Employee Benefits Alert
Final IRS Regulations on Employer Shared Responsibility
February 12, 2014
Private Client Alert
2014 Estate Planning: Should I Take Advantage of Portability?
December 23, 2013
Exempt Organizations Alert
New York Adopts Substantial Changes to Laws Regulating Nonprofits
December 20, 2013
Exempt Organizations Alert
Wisconsin Court Holds Parsonage Allowance Unconstitutional
November 27, 2013
Employee Benefits Alert
IRS Offers New Plan Design Option for Health FSAs
November 8, 2013
Tax Alert
DOJ Deal with Swiss Banks Impacts U.S. Taxpayers and Financial Firms Around the World
October 31, 2013
Exempt Organizations Alert
Washington Post Releases Database of Reported Nonprofit Asset Diversions
October 30, 2013
Employee Benefits Alert
PPACA After the Government Shutdown
October 17, 2013
Employee Benefits Alert
Transitional Reinsurance Program Fee Applies to Self-Insured Group Health Plans
October 1, 2013
Employee Benefits Alert
IRS Guidance Requires Recognition of Same-Sex Marriage for Employee Benefits
September 4, 2013
Exempt Organizations Alert
Stalled Applications for Section 501(c)(3) Status: Is it Time to Sue the IRS?
August 16, 2013
Private Client Alert
D.C. Repeals Tax on Municipal Bond Interest Income for Individuals
August 15, 2013
Exempt Organizations Alert
Exempt Organizations News Flash: Priority Guidance Plan
August 12, 2013
Employee Benefits Alert
PPACA 2014: The Implications for Employers
July 31, 2013
Employee Benefits Alert
HIPAA Compliance Deadline for 2013 Final Rules
July 24, 2013
Exempt Organizations Alert
Exempt Organizations News Flash: IRS Updates
June 28, 2013
Employee Benefits Alert
DOMA Ruling Affects Employee Benefits
June 27, 2013
Private Client Alert
DOMA's Demise Opens Door for Tax Refunds for Some Same-Sex Couples
June 26, 2013
Political Law Alert
Summary of New York's New Political Disclosure Rules for Nonprofits
June 21, 2013
Exempt Organizations Alert
Lessons Learned From the IRS Colleges & Universities Compliance Project
June 4, 2013
Employee Benefits Alert
IRS Finalizes Program for Pre-Approval of 403(b) Plan Documents
April 24, 2013
Business, Investment & Transactional Tax Alert
Global Netting: Potential Opportunities for Corporate Taxpayers
April 10, 2013
Political Law Alert
Amended MSRB Rules G-37 and G-8 Require Enhanced Disclosure
April 4, 2013
Political Law Alert
GAO Report Highlights Concerns Over Political Intelligence Disclosure
April 4, 2013
Employee Benefits Alert
New IRS Program for Retroactive Adoption of 403(b) Plan Documents
March 28, 2013
Private Client Alert
District of Columbia Alters Treatment of Municipal Bond Interest
March 26, 2013
International Tax Alert
Professional Golfer Sergio Garcia to Owe More Taxes on Endorsement Income
March 15, 2013
Political Law Alert
FEC Increases Contribution Limits
January 30, 2013
Private Client Alert
The Impact of the Fiscal Cliff Legislation: A Brief Window for Charitable IRA Rollovers
January 11, 2013
Private Client Alert
Fiscal Cliff Averted: Tax Consequences for High-Net-Worth Individuals
January 7, 2013
Employee Benefits Alert
The Impact of the Fiscal Cliff Legislation
January 4, 2013 - UPDATED January 23, 2013
Exempt Organizations Alert
IRS Issues Priority Guidance Plan
November 21, 2012
Exempt Organizations Alert
IRS Issues New Regulations for Foreign Grantmaking by Private Foundations
October 3, 2012
Political Law Alert
SEC & Massachusetts Sanction Goldman Sachs $16 Million, Underscoring Need for Vigorous Compliance With Pay-to-Play Rules
September 27, 2012
Exempt Organizations Alert
IRS Confirms Deductibility of Contributions to Domestic Disregarded Entities
August 3, 2012
Political Law Alert
DC Circuit Refuses to Stay Lower Court Ruling Requiring Disclosure of Funders of "Electioneering Communications"
May 15, 2012
Employee Benefits Alert
New Retirement Plan Fee-Disclosure Rules Now Finalized
April 5, 2012
Political Law Alert
President Obama Signs STOCK Act Into Law
April 5, 2012
Exempt Organizations Alert
Recent Developments
February 21, 2012
Political Law Alert
House Passes STOCK Act without "Political Intelligence Consultant" Requirements
February 9, 2012
Political Law Alert
Senate-Passed "STOCK Act" Requires "Political Intelligence Consultants" to Register and Report under Lobbying Disclosure Act
February 7, 2012
Private Client Alert
Federal Judge Grants IRS "John Doe" Summons Seeking California Gift Tax Records
December 22, 2011
Exempt Organizations Alert
How to Prevent Your Trademark From Becoming a .XXX Domain
October 14, 2011
Tax Alert
LB&I Commissioner Provides Guidance to Examiners and Managers on the Codified Economic Substance Doctrine and Related Penalties
July 29, 2011
Exempt Organizations Alert
The Gift Tax and Contributions to Section 501(c)(4) Organizations
July 11, 2011
Exempt Organizations Alert
The Gift Tax and Contributions to Section 501(c)(4) Organizations: Less than Meets the Eye?
June 14, 2011
International Tax Alert
Recent Developments Relating to FBARs and Offshore Voluntary Disclosure Program
June 6, 2011
The Supreme Court to Hear Arguments on Whether Loss Causation Must Be Established for Class Certification
April 21, 2011
Political Law Alert
The FEC Updates Contribution Limits
February 7, 2011
Private Client Alert
President Obama Signs Bill on Tax Cut Extensions
December 17, 2010
Exempt Organizations Alert
IRS Releases Draft of Core Form 990 for 2010
October 22, 2010
International Tax Alert
Certainty for Reporting Uncertain Tax Positions (UTP) to IRS
October 13, 2010
International Tax Alert
Recently Enacted Provisions Relating to the Foreign Tax Credit
October 8, 2010
International Tax Alert
More and More Transfer Pricing Enforcement in Store!
August 6, 2010
International Tax Alert
IRS Launches New "Transfer Pricing Practice" -- Pilot Program Will Select Audit Cases for Scrutiny
May 5, 2010
Employee Benefits Alert
PPACA and Beyond – Implications for Employers Today
April 30, 2010
Political Law Alert
House and Senate Respond to Citizens United Ruling
April 30, 2010
International Tax Alert
More Foreign Financial Account Reporting
March 26, 2010
International Tax Alert
Looking for FBARs in All the Wrong Places? Limited Relief in New Interim Guidance
March 15, 2010
Employee Benefits Alert
Get Ready for the Employment Tax Compliance Surge: IRS to Challenge Status of Independent Contractors
February 18, 2010
Political Law Alert
Schumer, Van Hollen Outline Legislative Response to Citizens United
February 12, 2010
Political Law Alert
Practical Impact and Longer Term Consequences of Citizens United v. FEC
January 25, 2010
Political Law Alert
Caplin & Drysdale Submits Comments to SEC on Proposed Pay to Play Law
October 8, 2009
Political Law Alert
Securities and Exchange Commission's Proposed Pay to Play Rule
October 1, 2009
Exempt Organizations Alert
Senate Chairman's Health Care Mark Lists Provisions for Nonprofit Hospitals
September 16, 2009
Employee Benefits Alert
IRS Proposes to Raise the Rank of Official Initiating Church Tax Inquiries, But Not High Enough
August 31, 2009
Political Law Alert
Proposed SEC Pay-to-Play Rule Will Soon Be Available for Public Comment
July 22, 2009
Political Law Alert
Congress Issues Clarification on Conditions for Lobbyist Termination
June 22, 2009
Political Law Alert
Obama Administration Restricts Lobbying on Stimulus Spending
March 26, 2009
Political Law Alert
New FEC Registration Forms Available; Lobbyist PACs Must Amend by March 29, 2009
March 12, 2009
Exempt Organizations Alert
IRS Articulates New Standards for Nonprofit Websites
February 27, 2009
Political Law Alert
Important Recent Developments on Lobbyist PACs, Obama Executive Order and LDA Registration
February 18, 2009
Employee Benefits Alert
Section 457A and Interim Guidance under Notice 2009-8
February 10, 2009
Employee Benefits Alert
Income Inclusion and Correction under Section 409A
February 10, 2009
Employee Benefits Alert
403(b) Plans
February 10, 2009
Employee Benefits Alert
Bona Fide Severance Plan and Substantial Risk of Forfeiture under Section 457
February 10, 2009
Published Articles & Books
VIEWPOINT: Digital Services Taxes: How Did We Get Into This Mess?
Tax Notes Federal
March 23, 2020
BLOG: IRS Release Clarifications for Form 8082
www.PartnershipRepresentative.com
March 19, 2020
VIEWPOINT: The U.S. Foreign Tax Credit Limitation: How It Works, Why It Matters
Tax Notes Federal
March 9, 2020
BLOG: IRS Release Draft Instructions to Form 8978
www.PartnershipRepresentative.com
February 26, 2020
BLOG: State Department Designates Chinese Media Outlets as "Foreign Missions"
February 21, 2020
BLOG: Department of Education Provides Clarity on Reporting of Foreign Gifts to U.S. Universities
www.FARA.us
February 4, 2020
Interpreting the TCJA: Standing Up (With Reservations) for Treasury
Tax Notes Federal Letters to the Editor
January 27, 2020
Appeal or No Appeal
: In Stipulations, Silence on Appellate Rights Could Mean Waiver
January 9, 2020
INSIGHT: 2020 Vision for State and Local Tax
Bloomberg Tax: Daily Tax Report
December 27, 2019
Go BIG! How to Build a Tax Effort Worthy of the Belt and Road Initiative
Journal of International Taxation in China
December 11, 2019
BLOG: IRS Releases Interim Guidance Centralized Partnership Audit Regime
www.PartnershipRepresentative.com
November 27, 2019
U.S. Tax Policy and Cross-Border Investments in 2019: The General Picture
Rivista di Diritto Tributario Internazionale - International Tax Law Review
November 12, 2019
BLOG: IRS Releases Interim Guidance on BBA Partnership Audit Procedures
www.PartnershipRepresentative.com
October 24, 2019
BLOG: Venture Capitalist Agrees to Plead Guilty to FARA Violations
www.FARA.us
October 24, 2019
BLOG: Department of Education Investigates Foreign Gifts to U.S. Universities
www.FARA.us
October 22, 2019
Sharia Law Is Already Here - The IRS Must Respond
The Hill Op-Ed
October 18, 2019
We Have No Idea Who is Paying Rudy Giuliani
The Washington Post Op-Ed
October 10, 2019
SPECIAL REPORT: I'm Looking Through You, You're Not The Same: Partnership-Held CFCs
Tax Notes Federal
October 7, 2019
Financier Worldwide Annual Review: Transfer Pricing 2019 – United States
Financier Worldwide
October 7, 2019
BLOG: Judge Throws Out Foreign Agent Conviction of Former Michael Flynn Associate
www.FARA.us
October 7, 2019
BLOG: DOJ Official Confirms that FARA is a "Top Priority"
www.FARA.us
September 27, 2019
COMMENTARY & ANALYSIS: The TCJA and the Treaties
Tax Notes International Magazine
September 9, 2019
BLOG: Two Russian FARA-Related Cases Still Pending
www.FARA.us
August 21, 2019
SDNY Distinguishes Supreme Court, Holds Tribune Company's Leveraged Buyout Falls Within Section 546(e) Safe Harbor Provision
August 20, 2019
Decrypting The New IRS Cryptocurrency Compliance Letters
Law360 Tax Authority
August 7, 2019
Understanding FARA and Promoting Law Firm Compliance
ALAS Loss Prevention Journal
August 6, 2019
BLOG: Former Michael Flynn Associate Convicted Under FARA
www.FARA.us
July 25, 2019
BLOG: Remember That You Must Appoint a Partnership Representative with Extended Form 1065 for the 2018 Tax Year
www.PartnershipRepresentative.com
July 25, 2019
When a Cyberattack Might Be Espionage: DC Circuit Decides
In re U.S. Office of Personnel Management Data Security Breach Litigation
July 19, 2019
Garvin
and its Aftermath: The Ninth Circuit Upholds a Bankruptcy Plan Contemplating Income From a Cannabis-Related Source and Several Bankruptcy Courts Quickly Weigh In
July 8, 2019
Combating Aggressive Tax Planning Through Disclosure: A Comparison of U.S. and EU Rules Applicable to Tax Advisors
ABA Tax Times
June 14, 2019
BLOG: NDAA Carries New Disclosure Requirements For U.S.-Based Foreign Media Outlets
www.FARA.us
June 11, 2019
Supreme Court Alert: The Court Holds That Third-Party Counterclaim Defendants Cannot Remove Cases to Federal Court
June 6, 2019
BLOG: Could The Fugees' Pras Michel Be Charged with a FARA Violation?
www.FARA.us
May 23, 2019
Beyond the Board: Alternatives in Nonprofit Corporate Governance
Harvard Business Law Review Online Volume 9
May 14, 2019
BLOG: DOJ Wins First FARA Civil Enforcement Case Since 1991
www.FARA.us
May 8, 2019
Deductibility of Illegal Payments, Fines, and Penalties
(Book)
Bloomberg Tax 524-2nd Tax Management Portfolio
May 3, 2019
Supreme Court Alert: A Divided Court Holds that Under the Federal Arbitration Act an Ambiguous Agreement Cannot Provide a Basis for Compelling Class Arbitration
Lexology
May 1, 2019
Applying for Federal Tax-Exemption Under Section 501(c)(3)
Practical Law
April 26, 2019
Ex-NFL Player's Future Concussion Settlement Payments are Protected from Creditors in Bankruptcy
Lexology
April 25, 2019
BLOG: Recent Developments in Florida Broadcasting Company's Suit Against DOJ Over FARA Registration Requirement
www.FARA.us
April 3, 2019
BLOG: IRS Publishes New Form 8981 and Form 8984
www.PartnershipRepresentative.com
March 19, 2019
BLOG: DOJ's Push to Register State-Run Media Under FARA
www.FARA.us
March 13, 2019
Deal or No Deal: The Unknown Cost of the IRS's New Voluntary Disclosure Practice
White Collar Crime Committee Newsletter
February 28, 2019
BLOG: Recent Developments in FARA: Michael Cohen Hearing
www.FARA.us
February 28, 2019
BLOG: Updates on Congressional Action on FARA Reform
www.FARA.us
February 20, 2019
IRS Weapons Against Aggressive Tax Planning
Trusts & Trustees
February 19, 2019
BLOG: Recent FARA Development: Skadden Pays $4.6 Million in Settlement
www.FARA.us
February 15, 2019
BLOG: The Foreign Agents Registration Act: A Brief Plain-Language Guide
www.FARA.us
February 13, 2019
BLOG: FAQs About Letters of Inquiry from the Department of Justice FARA Unit
www.FARA.us
January 22, 2019
EXPERT ANALYSIS: Planning For Partnership Representatives In The New Year
Law360
January 4, 2019
Agency PE: Case Study, Questions and Expert Speak
IFA India Newsletter
January 1, 2019
BLOG: Tax Court Rules - Partnership Representative
www.PartnershipRepresentative.com
December 28, 2018
Trump's Claim That He Didn't Violate Campaign Finance Law Is Weak -- and Dangerous
The Washington Post Op-Ed
December 14, 2018
Recent Sixth Circuit Decision Clarifies Appealability of Bankruptcy Court Orders
Lexology
December 11, 2018
BLOG: IRS Publishes Draft Instructions for Form 8979, Partnership Representative Revocation, Designation, and Resignation Form
www.PartnershipRepresentative.com
December 5, 2018
Navigating QBAI Quirks of the GILTI Regulations
Bloomberg Tax, Tax Management International Journal
November 5, 2018
COMMENTARY & ANALYSIS: The BEAT and the Treaties
Tax Notes International Magazine
October 15, 2018
Limiting Liabilities: Structuring Holding Companies to Withstand Insolvency
IR Global
September 27, 2018
SPECIAL REPORT: The Nitty-Gritty of FDII
Tax Notes
September 17, 2018
INSIGHT: People, Places, and Things: Final Regulations on the Eligibility, Designation, Revocation, and Authority of Partnership Representatives
Bloomberg Tax: Daily Tax Report
September 11, 2018
Trump Says Michael Cohen Didn't Commit Crimes. He's Wrong.
The Washington Post
August 24, 2018
Current Issues in Chapter 15 Discovery
International Law Office
August 24, 2018
SDNY Bankruptcy Court Enters Final Default Judgments Against Properly Served Foreign Defendants
Lexology
August 22, 2018
Mergers, Acquisitions, and Conversions in the Context of Nonprofit Organizations
ABA Business Law Today
August 14, 2018
Second Circuit Holds Arbitration of Alleged Violation of Discharge Injunction Conflicts with Purposes of Bankruptcy Code
Lexology
June 29, 2018
Kumquat: The U.S. International Tax Issues
Tax Notes International Magazine
June 25, 2018
EXPERT ANALYSIS: U.S. Owners of Foreign Trusts Face Increased IRS Scrutiny
Law360
June 21, 2018
How Will Section 546(e) Apply to Public Securities Transactions in Wake of Merit Management?
International Law Office
May 25, 2018
There's No Elephant in This Mousehole: The Supreme Court Upholds State Court Jurisdiction Over Class Actions Brought Under the Securities Act of 1933
Lexology
May 18, 2018
The Point of Paying Stormy Daniels Was to Keep Voters from Hearing Her Story
The Washington Post
May 4, 2018
Mining for Meaning: An Examination of the Legality of Property Rights in Space Resources
Virginia Law Review
May 1, 2018
INSIGHT: Last Call for OVDP: Use It or Lose It
Bloomberg Tax: Daily Tax Report
April 20, 2018
Is "Per Debtor" Better? Cases Analyzing Cramdown and Substantive Consolidation Reflect Ongoing Debate About Creditor Protections in Multi-Debtor Bankruptcies
Lexology
April 19, 2018
Chapter 9: Filing Claims and Suits for Refund of Overpayments
American Bar Association
April 9, 2018
Supreme Court Alert: The Court Provides Additional Guidance on the Appropriate Level of Review of Determinations of Mixed Questions of Law and Fact by the Bankruptcy Court
Lexology
March 19, 2018
INSIGHT: BEAT Strikes the Wrong Note
Bloomberg Tax: Daily Tax Report
March 16, 2018
Narrower Harbors: Supreme Court Holds that § 546(e) Securities Safe Harbor Does Not Protect Transfers in Which Financial Institution Is Only a Conduit
Lexology
March 16, 2018
The First Circuit Joins Several Other Circuit Courts in Finding That Creditors' Committees Have an Unconditional Right to Intervene in Adversary Proceedings
Harvard Law School Bankruptcy Roundtable
March 13, 2018
Bringing Attorneys Together to Strengthen Diversity and Inclusion Efforts
The Legal Intelligencer
March 9, 2018
Following The Money: Trends in Cross-Border Asset Recovery
IR Global
March 6, 2018
With 2018 Midterms Approaching, Our Elections Are Not Protected
The Hill Op-Ed
March 6, 2018
INSIGHT: First Class, Global Entry, and Now Tax Compliance: the New Must-Have for Today's International Traveler
Bloomberg Tax: Daily Tax Report
March 6, 2018
Choice of Law Issues in the Hyundai & Kia Fuel Economy Litigation: Toward a New Predominance Analysis?
Lexology
February 12, 2018
GILTI Pleasures
Tax Notes International Magazine
February 12, 2018
Risk of Harm Standing in Data Breach Cases - Latest Developments
Lexology
February 9, 2018
First Circuit Finds Creditors' Committees Have Unconditional Right to Intervene in Adversary Proceedings
International Law Office
February 9, 2018
The First Circuit Joins Several Other Circuit Courts in Finding That Creditors' Committees Have an Unconditional Right to Intervene in Adversary Proceedings
Lexology
January 23, 2018
United Nations Handbook on Selected Issues in Protecting the Tax Base of Developing Countries - Chapter IV: Limiting Interest Deductions
United Nations
January 22, 2018
U.S. Plays Lone Ranger on International Tax to Its Detriment
The Hill Op-Ed
January 19, 2018
International Aspects of U.S. 'Tax Reform' -- Is This Really Where We Want to Go?
International Tax Report
January 2, 2018
David Rosenbloom Comments on Tax Bills' Impact on Earnings of U.S.-Owned Foreign Corporations
The Washington Post Op-Ed
December 3, 2017
A New Way to Safeguard America Against Threats to Our Elections
The Hill Op-Ed
November 1, 2017
Church-Affiliated Organizations Face New Challenges After
Advocate
Taxation of Exempts
October 26, 2017
Supreme Court to Consider Statutory Safe Harbor for Debtors' Pre-Petition Securities Transactions
International Law Office
September 29, 2017
Low-Tax Texas Should Pay Its Fair Share of Harvey Costs
The Washington Post Op-Ed
September 6, 2017
"Free and Clear" Bankruptcy Sale Orders and State Law Successor Liability Claims: The Overlooked Question of Preemption
American Bankruptcy Institute Law Review
August 31, 2017
Avoiding the Voidable: Assessing Global Insolvency Practices and Processes
IR Global
August 21, 2017
Trevor Potter: Presidential Election Commission Focused on Manufacturing Evidence to Support Its Own Foregone Conclusions
YubaNet.com Op-Ed
July 19, 2017
Foreword for Asian Voices: BEPS and Beyond
International Bureau of Fiscal Documentation (IBFD)
July 1, 2017
BEPS: The Corporate Tax Leader's Perspective
International Bureau of Fiscal Documentation (IBFD)
July 1, 2017
Sexton Opinion Further Restricts What Conduct Can Be Regulated Under "Practice" Before the IRS
ABA Tax Times
June 1, 2017
U.S. Corporate Tax Reform and Wallace Stevens
Tax Notes
May 30, 2017
Churches Cannot be Allowed to Become Political Dark Money Shops
The Hill Op-Ed
May 4, 2017
Pro Bono Program Helps Low-Income Philadelphians
Philadelphia Bar Reporter
May 1, 2017
Beth Shapiro Kaufman Comments on Extension of Time to Make Portability Election: Additional Remedies
Courtesy: Leimberg Information Services, Inc. (LISI) at LeimbergServices.com
April 18, 2017
The Destination-Based Cash Flow Tax Is a VAT?
Tax Notes
March 29, 2017
Qualified Retirement Plans In 2017 and Beyond: First Operational Compliance List Issued
International Law Office
March 24, 2017
Chapter 15 at 11: Threshold Requirements for Recognition
International Law Office
March 24, 2017
The Important Money-in-Politics Questions to Ask Judge Gorsuch
The Hill
March 18, 2017
Transfer Pricing Forum
Bloomberg BNA
March 17, 2017
"Free And Clear" Bankruptcy Sales and Successor Liability in the United States
Caplin & Drysdale
March 16, 2017
Captive Insurance: State Reporting Obligations for Transactions of Interest
International Law Office
March 3, 2017
U.S. Corporate Tax Reform and Jean-Paul Sartre
Tax Notes
March 1, 2017
IRS Launches Issue-Based Corporate Compliance Campaigns
International Law Office
February 24, 2017
Where Have All the Transfer Pricing Safe Harbors Gone? A Plea for Reinvigoration
Bloomberg BNA, Tax Management Transfer Pricing Report
February 23, 2017
Will Border Adjustment Tax End Transfer Pricing as We Know It?
Bloomberg BNA, Tax Management Transfer Pricing Report
February 23, 2017
IRS Launches Issue Based Corporate Compliance Campaigns
Global Tax Weekly
February 16, 2017
Reconsidering European Court of Justice Jurisprudence on Limitation on Benefits Clauses: Why the U.S. Should Care
46 TM Int'l J. 83, Bloomberg BNA Tax Management International Journal
February 10, 2017
Syndicated Conservation Easement Transactions Identified as New 'Listed Transactions'
International Law Office
January 27, 2017
Attributes of Excellence: Governance, Risk Management, and Compliance of Health Care Organizations
Enterprise Risk Management for Healthcare Entities
January 25, 2017
The U.S. Must Avoid This Untested Approach To International Taxes
The Hill Op-Ed
January 24, 2017
The New Partnership Audit Regime: What We Know, What We Do Not and What Is Next
Tax Management Memorandum, Bloomberg BNA
January 23, 2017
Treasury Issues Regulations Addressing Use of LLCs to Disguise Beneficial Ownership
International Law Office
January 20, 2017
Qualified Retirement Plans In 2017 and Beyond: Resources And Considerations for Employers
International Law Office
January 13, 2017
Donald Trump Hasn't Solved Any of His Conflicts of Interest. He Could Have. He Chose Not To.
The Washington Post
January 11, 2017
Office of Congressional Ethics Too Important to be a Tweet Away From Death
The Hill Op-Ed
January 11, 2017
Tax Claims - Court of Federal Claims: Jurisdiction, Practice, and Procedure
Court of Federal Claims: Jurisdiction, Practice, and Procedure
January 9, 2017
Congress Looks to Fix New Partnership Audit Rules
International Law Office
January 6, 2017
Chapter 15 at 11: Chapter 15 Provides Provisional Relief in Hanjin Shipping
International Law Office
January 6, 2017
Tax Plans Compared (December 2016) Corporate Tax
Global Tax Weekly
January 5, 2017
Voluntary Disclosure Window Closing for Bitcoin
International Law Office
December 16, 2016
Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations
International Law Office
November 25, 2016
How President Trump Could Use the White House to Enrich Himself and His Family
The Washington Post
November 18, 2016
Financier Worldwide Annual Review: Transfer Pricing 2016 – United States
Financier Worldwide
November 16, 2016
Commentary: These ballot initiatives could help fix our broken election system
Reuters
November 7, 2016
New Regulations Change Allocation of Partnership Liabilities
International Law Office
November 4, 2016
New Regulations Change Allocation of Partnership Liabilities
Global Tax Weekly
November 3, 2016
The U.S. Country-by-Country Reporting Regulations: A Synopsis
Global Taxation
October 1, 2016
Chapter 15 at 11: Bankruptcy Code's Cross-Border Insolvency Law Approaches 11th Anniversary
International Law Office
September 30, 2016
On the Centennial Anniversary of the Estate Tax
Estate Planning Magazine
September 23, 2016
The Continuing Irony of "Tort Reform"
Mealey's Litigation Report: Asbestos
September 14, 2016
U.S. Tax Enforcers React to The Panama Papers
IFC Review
September 1, 2016
Donald Trump and the 'Rigged' Election
The Hill
August 11, 2016
Muhammad Ali in the Time of the 'Maxi Tax'
Tax Notes
August 8, 2016
Supreme Court to Review Priority-Skipping Settlement and Structured Dismissal of Chapter 11 Case
International Law Office
August 5, 2016
Is the United States Still a Tax Haven? The Government Acts on Tax Compliance and Money Laundering Risks
CCH's Journal of Tax Practice & Procedure
July 25, 2016
Supreme Court Nixes Puerto Rico Insolvency Law, but Congress Legislates New Path
International Law Office
July 22, 2016
Proposed 457 Regulations: Bona Fide Severance Pay Plan and Substantial Risk of Forfeiture
International Law Office
July 22, 2016
Delaware Bankruptcy Court Reaffirms the Viability of Class Proofs of Claim in PacSun Bankruptcy
Lexology
July 18, 2016
Report of Foreign Bank and Financial Accounts (FBAR)
(Book)
Bloomberg BNA's Tax Management Portfolio
June 29, 2016
Do Bankruptcy Code Clawback Provisions Reach Transactions Occurring in Other Countries?
International Law Office
June 17, 2016
Wealth Inequality, Tax Policy, and the 2016 Elections
Estate Planning
June 1, 2016
IRS to Hire 700 for Civil and Criminal Tax Enforcement
International Law Office
May 20, 2016
Court Holds that Bankruptcy Code Pre-Empts State Laws Invoked by Creditors to Avoid LBO Payments
International Law Office
May 6, 2016
Financier Worldwide 2016 Global Tax Annual Review – United States
Financier Worldwide
April 27, 2016
Products Liability Plaintiffs Prevented From Seeking Recovery Against New GM Because the Bankruptcy Court Found Their Claims Were Not Assumed by New GM
Lexology
April 26, 2016
IRS Seeks Comments for New Tax Examination and Collection Regime
International Law Office
April 8, 2016
US Congress Enacts Entirely New Tax Examination and Collection Regime for Partnerships and LLCs
Family Office Elite Magazine
April 1, 2016
Seventh Circuit Rules on Authority to Temporarily Stay Non-Debtor Litigation
International Law Office
March 25, 2016
Do Theories Trump Facts Under the U.S. Arm's Length Standard? Is the BEPS Pricing Guidance on Intangibles Consistent with the U.S. Law?
BNA Tax Management Transfer Pricing Report
March 17, 2016
IRS Criminal Investigation: A National Asset Being Damaged
Tax Notes
March 14, 2016
Second Circuit Determines that Argentine Central Bank is Not Alter Ego of Argentina
International Law Office
March 11, 2016
DOL Releases 2015 Form 5500 Including New IRS Compliance Questions
International Law Office
March 11, 2016
2016 Federal Tax Benefits for Hiring Qualified Veterans, National Guard Members and Reservists
(Book)
Caplin & Drysdale, Chartered
March 1, 2016
2016 Tax Planning Ideas for People 50+
Next Avenue
February 26, 2016
Coca-Cola Company Challenges $9 Billion Transfer Pricing Adjustment
International Law Office
February 5, 2016
Congress Enacts New Tax Examination and Collection Regime for Partnerships
International Law Office
January 22, 2016
U.S. Passports in Jeopardy for Taxpayers Owing the IRS
Global Tax Weekly
January 11, 2016
The Ethical Limits of Tax Planning
Trusts and Trustees
January 6, 2016
Allocating Generation-Skipping Transfer Tax Exemption
California Trusts and Estates Quarterly
December 30, 2015
Derivative Benefits and Equivalent Beneficiaries - What Are We Talking About? Part II
International Tax Report
December 10, 2015
Derivative Benefits and Equivalent Beneficiaries - What Are We Talking About? Part I
International Tax Report
November 5, 2015
Response to Final OECD BEPS Tome
International Law Office
October 30, 2015
‘Just Add SaLT!' When and How to Consider State Tax Ethical Issues in Advising Clients
ABA Tax Times
October 30, 2015
First Circuit Decision Fails to Relieve Puerto Rico's Debt Crisis
International Law Office
October 16, 2015
Tax Court Decision in Altera Overturns Important Transfer Pricing Regulations
The National Law Review
October 2, 2015
IRS Releases Guidance on Voluntary 2015 PPACA Information Reporting
International Law Office
October 2, 2015
A Critique Of RAND's Three Reports On Asbestos Trusts And Asbestos Litigation
MEALEY'S Asbestos Bankruptcy Report
September 25, 2015
Steering the Cadillac Tax: An Additional Opportunity for Employers and Other Stakeholders
International Law Office
September 18, 2015
Transfer Pricing Audits: Flipping the Tested Party
International Law Office
August 28, 2015
Applying Tobacco Tax Lessons to Sugary Drinks
University of Pennsylvania Law School, The Regulatory Review
August 27, 2015
Transfer Pricing Audits: Flipping the Tested Party
Wolters Kluwer
August 27, 2015
IRS Releases Guidelines for Examining CFC Transactions
International Law Office
August 21, 2015
The Tax Planner's Tightrope: Morality and Politics Now in Play
International Law Office
August 14, 2015
The Need for Federal Oversight of Tax Preparers
University of Pennsylvania Law School, The Regulatory Review
August 10, 2015
Supreme Court: Decisions Denying Plan Confirmation Not Appealable as of Right
International Law Office
August 7, 2015
The Practical Protection of Taxpayers' Fundamental Rights
International Fiscal Association 2015 Basel Congress
August 1, 2015
The Intersection of U.S. Tax Treaty Policy, Tax Reform, and BEPS
International Law Office
July 24, 2015
Moore
Requires 'More' Scrutiny of IRS-Imposed FBAR Penalties Under the Administrative Procedures Act
Family Office Elite Magazine
July 17, 2015
FATCA – Enforcement Win or Expatriate Generator?
IFC Review
July 1, 2015
Fairfield Sentry and the Limits of Comity in Chapter 15 Cases
International Insolvency Law Review
July 1, 2015
Supreme Court Rejects Stripping-Off of Underwater Mortgages in Bankruptcy
International Law Office
June 26, 2015
Shortchanged: How Wage Theft Harms Pennsylvania's Workers and Economy
Sheller Center for Social Justice: Temple University Beasley School of Law
June 24, 2015
Wellness International: Litigants May Consent to Adjudication by Bankruptcy Courts
International Law Office
June 19, 2015
HR1104 Would Unintentionally Eliminate Private Foundation Safeguards
The Hill
June 16, 2015
Treasury Proposes Significant Changes to Model Tax Treaty
International Law Office
June 12, 2015
Treasury Proposes Significant Changes to U.S. Model Treaty
Global Tax Weekly
June 4, 2015
Reflections on the Intersection of U.S. Tax Treaty Policy, U.S. Tax Reform, and BEPS
Tax Notes International
May 25, 2015
Supreme Court Considers Junior Liens on 'Underwater' Property
International Law Office
May 22, 2015
The Tax Planner's Tightrope: Morality and Politics Now in Play
IFC Economic Report
May 5, 2015
To Get Ahead in Congress: Skip Governing, Raise Money
POLITICO Magazine
April 6, 2015
Steering the Cadillac Tax: An Opportunity for Employers and Other Stakeholders
International Law Office
March 20, 2015
Fairfield Sentry and the Limits of Comity in Chapter 15 Cases
International Law Office
March 20, 2015
IRS Releases Additional Guidance on Reporting Health Coverage Information
International Law Office
March 13, 2015
Abusive Small Captive Insurance Companies on IRS 'Dirty Dozen' List
International Law Office
February 27, 2015
Filing Claims and Suits for Refund Overpayments
American Bar Association, Section of Taxation
February 25, 2015
Proposed New York Tax Changes Would Affect Large and Small Businesses
International Law Office
January 30, 2015
Here's What I Learned When I Helped Stephen Colbert Set Up His Super PAC
The Washington Post
January 21, 2015
When It Comes to Money in Politics, The Supreme Court Lives in a Different Reality
Thomson Reuters
January 16, 2015
Inherited IRAs in the Crosshairs
Estate Planning Magazine
December 30, 2014
Appeal Court Expands Stockbroker Defence to Non-Securities Transactions
International Law Office
December 19, 2014
How Stephen Colbert Schooled Americans in Campaign Finance
TIME Magazine
December 16, 2014
Will the Rush to Invert Spur Corporate Tax Reform? A Conversation
Tax Notes International
December 15, 2014
The Current State of Expatriation
ALI CLE Estate Planning Course Materials Journal
December 1, 2014
IRS May Restrict Informal Refund Claims for LB&I Taxpayers Under Exam
Procedurally Taxing
November 26, 2014
GM Tests the Limits of Liability Post-Bankruptcy
Trial Magazine
November 17, 2014
IRS Power To Regulate Tax Practitioners Slipping Away
Forbes
November 10, 2014
OECD Releases Finalized Proposals on Key Tax Base Erosion Concerns
Global Tax Weekly
November 6, 2014
Op-Ed: A 'People's Pledge' Could Quell The Politics in Judicial Elections
The National Law Journal
November 3, 2014
Changes to the Uniform Fraudulent Transfer Act Approved
International Law Office
October 10, 2014
U.S. Offshore Account Enforcement Issues
CCH's Journal of Tax Practice & Procedure
September 30, 2014
Supreme Court on Powers of Bankruptcy Courts After Stern
International Law Office
September 26, 2014
Third Circuit Rules Failure to Appeal Leaves Union and its Retirees Without a Remedy
Lexology
September 9, 2014
IRS Issues Final Regulations On Material Advisor Penalties
Global Tax Weekly
September 4, 2014
Recent Changes in Circular 230: Where Are We Now?
Real Estate Journal
September 3, 2014
IRS Issues Final Regulations on Material Adviser Penalties
International Law Office
August 29, 2014
Litigation Claimants Get a Second Chance in Bankruptcy Appeal
Lexology
July 25, 2014
Recent IRS Activity Focuses on Non-Qualified Deferred Compensation Plans
International Law Office
July 25, 2014
Remain Vigilant On Indian Permanent Establishments, Even After the Favorable e-Funds Decision
Global Tax Weekly
July 10, 2014
Clearing Up the False Premises Underlying the Push for Asbestos Trust 'Transparency'
23 Widener J. Pub. L. 725
June 30, 2014
OECD's Proposed New Approach to Transfer Pricing of Intangibles: A Critique
New York University
June 29, 2014
IRS Issues Guidance on Application of
United States v. Windsor
International Law Office
June 20, 2014
Limitations on Corporation's Ability to Free Itself from Legacy Liabilities
International Law Office
June 20, 2014
IRS Modifies Programme for Pre-approval of Section 403(b) Plan Documents
International Law Office
June 6, 2014
Visions of Tax Reform Without Estate Tax Changes
Estate Planning Magazine
June 2, 2014
Creditor Standing to Bring Third-Party Actions Outside Bankruptcy Proceedings
International Law Office
May 23, 2014
Strategies for Current Filings of Noncompliant Taxpayers as FBAR Deadline Approaches
Practical Tax Strategies
May 23, 2014
Jurisdictional Limits on Recognition of Foreign Non-Debtor Releases
International Law Office
May 2, 2014
Here Comes FATCA…What To Expect In 2014
IFC Review Monthly e-Journal
April 1, 2014
Enforcing International Arbitration Clauses in Bankruptcy Proceedings
International Law Office
March 21, 2014
The New APMA Procedures — Cosmetic or Cosmic?
Tax Management International Journal
March 14, 2014
Enforcing Non-U.S. Tax Authority Requests for Taxpayer Information
International Law Office
March 7, 2014
Safe Harbour Neither Bars Nor Pre-empts State Law Fraudulent Transfer Claims
International Law Office
February 21, 2014
6 Reasons U.S. Taxpayers Should Report Assets Held in Swiss Banks Soon
Client Alert
February 3, 2014
Supreme Court to Rule on Adjudicatory Authority of Bankruptcy Judges
International Law Office
January 17, 2014
Surprise! Your Foreign Tax Credit Is Not Allowed Under Section 901(I)
Tax Notes International
January 14, 2014
Washington Tax Roundup
Washington Jewish Week
January 8, 2014
A New Tax-and-Spend Strategy to Fight Obesity
University of Pennsylvania Law School, The Regulatory Review
January 6, 2014
Here Comes FATCA…What to Expect in 2014
IFC Review
January 4, 2014
Political Activity, Lobbying Laws, and Gift Rules Guide
(Book)
West Publishing, 3d, 2013-2014 ed.
January 1, 2014
Weighing Fiduciary Duties with 21st Century Realities – Evaluating the Viability of Remote Participation for Boards of Directors
1 Emory Corp. Governance & Accountability Rev. 43
January 1, 2014
The Current State of Expatriation
A Guide to International Estate Planning, American Bar Association, 2nd Ed.
December 31, 2013
FATCA: An Overview of Its Scope and Application to Non-U.S. Entities Chapter
The International Comparative Legal Guide to: Private Client 2014, 3rd Edition
December 23, 2013
Jurisdictional Uncertainty in Trust Fund Recovery Penalty Cases
Tax Notes, p. 963
December 16, 2013
A Rant About the Implications of an IRS Scandal
Estate Planning Magazine
December 2, 2013
Overview of the OECD'S Action Plan on Base Erosion and Profit Shifting
Corporate Taxation
November 1, 2013
The Supreme Court Needs to Get Smarter About Politics
The Washington Post
October 11, 2013
The Justice Department and Swiss Banks: Understanding the Special Disclosure Program
Bloomberg BNA
September 24, 2013
Allocation of Indexed GST Exemption
Courtesy: Leimberg Information Services, Inc. (LISI) at LeimbergServices.com
September 11, 2013
Tax Implications of Natural Disasters
ABA Section of Taxation and Section of Real Property, Trust & Estate Division
September 1, 2013
Me, Myself, and My Subsidiary: A Shift in the Intent Standard in Related-Party Hybrid Debt Cases
Corporate Taxation
September 1, 2013
Pre-Bankruptcy LBOs as Fraudulent Transfers
The Review of Banking & Financial Services
August 1, 2013
Amazon.com v. Commissioner: Veritas
Redux?
Corporate Taxation
August 1, 2013
Here Are the Implications of Singapore's Move to FATCA Compliance
Singapore Business Review
July 29, 2013
The Crucial Implications of FATCA for U.S. Citizens in Hong Kong
Hong Kong Business
July 25, 2013
FATCA Reporting – Are Trusts and Trustees Caught in the Net?
Financier Worldwide
July 1, 2013
2013 Federal Tax Benefits for Hiring Qualified Veterans, National Guard Members and Reservists
(Book)
Caplin & Drysdale, Chartered
June 3, 2013
Transfer Tax Certainty is Finally Here! What Now?
Estate Planning Magazine
June 1, 2013
The History of Undisclosed Spending in U.S. Elections & How 2012 Became the "Dark Money" Election
27 Notre Dame Journal of Law, Ethics & Public Policy 384
June 1, 2013
A New Recipe for Election Reform
The Washington Post
May 9, 2013
Low-Income Students Must Aim High, Seize Opportunities Offered to Them
Detroit Free Press
May 7, 2013
Global Netting: Potential Opportunities for Corporate Taxpayers
WTE Practical International Tax Strategies, Volume 17, Number 8
April 30, 2013
A Simple Plan to Drastically Improve Voting, Stop Fraud, and Save Money
The Atlantic
April 18, 2013
Stipulation Limiting Damages Cannot Circumvent CAFA Jurisdiction
Caplin & Drysdale
March 26, 2013
The Rescission Decision
Tax Talk, Section of Taxation, Maryland State Bar Association
March 1, 2013
Cruising Toward Safe Harbors for Transfer Pricing?
Corporate Taxation
March 1, 2013
Mutual Administrative Assistance in Tax Matters
Journal of Corporate Taxation
March 1, 2013
The Effrontery of The Asbestos Trust Transparency Legislation Efforts
Mealey's Litigation Report Asbestos
February 20, 2013
Demystifying the IRS Guidance Process
Estate Planning Magazine
February 1, 2013
Campaign Finance: Remedies Beyond the Court
Democracy: A Journal of Ideas
January 8, 2013
Business Ethics
Handbook on the Economics of Reciprocity and Social Enterprise (with Russell G. Pearce)
January 1, 2013
U.K. Excess Profits Tax Under U.S. Foreign Tax Credit
Corporate Taxation
January 1, 2013
Recent Developments: U.K. Excess Profits Tax Under the U.S. Foreign Tax Credit
Corporate Taxation
January 1, 2013
Transfer Pricing: Rules and Practice in Selected Countries (H-1), No. 6955
Bloomberg BNA Tax Management Portfolio
January 1, 2013
Letters of Wishes and Protectors as Devices to Further the Settlor's Purposes
A Guide to International Estate Planning, American Bar Association, 2nd Ed.
January 1, 2013
'Do you have that new church app for your iPhone?' Making the Case for a Clearer and Broader Definition of Church Under the Internal Revenue Code
46 Creigh. L. Rev. 173
January 1, 2013
FATCA: A New Era of Financial Transparency
AICPA's Journal of Accountancy
January 1, 2013
A Deeper Democracy Begins with Proper Elections: Citizens United, the Rise of the Super PAC and the Loss of Electoral Integrity in the US
University of Oxford and University of Cambridge
December 20, 2012
Re-Membering The Nonprofit -- Uses of Members in Corporate Governance
Taxation of Exempts
December 1, 2012
The Nuts And Bolts of Deficiency Cases: From Examination to The Tax Court
The Practical Tax Lawyer
December 1, 2012
In Memoriam: Judge Lapsley W. Hamblen Jr.
Tax Notes
November 26, 2012
Foreign Official' Under FCPA: Regal May Be Legal
Law360
October 23, 2012
Supreme Court to Consider Impact of Stipulation Limiting Damages on CAFA Jurisdiction
Lexology
September 10, 2012
Safe at Last? Transfer Pricing Safe Harbors on the Horizon
Bloomberg BNA
September 6, 2012
No Oracle Could Have Foreseen Oracle's FCPA Settlement
Law360
September 5, 2012
Is the Limited Scope Marketed Opinion Preparing for a Comeback?
Tax Talk, Section of Taxation, Maryland State Bar Association
September 1, 2012
Federal Tax Rules Should Not Be Used to Limit Trust Duration
Tax Notes
August 13, 2012
IRS Guidance on Ongoing Offshore Voluntary Disclosure Program
Client Alert
July 19, 2012
Three Can Keep a Secret, If Two of Them Are Dead: A Thought Experiment Around Compelled Public Disclosure of "Anonymous" Political Expenditures
University of Virginia Journal of Law & Politics, Volume 27:609-625, 2012
July 1, 2012
What You Really Need to Know About Transfer Pricing
The Metropolitan Corporate Counsel, Inc.
July 1, 2012
Article from Tax Analysts, Switzerland and the U.S.: What We Have Here is a Failure to Communicate
Tax Analysts, by H. David Rosenbloom
June 4, 2012
Primary Concerns: Canvassing Transfer Tax Proposals
Estate Planning Magazine
June 1, 2012
Foreign Tax Credit Generators
Corporate Taxation
May 1, 2012
Offshore Tax Evasion: US Initiatives
Practical Law Company
April 26, 2012
Case Updates-Dell Products (Norway) General Electric Capital (Canada) SNF (Australia)
Corporate Taxation
March 1, 2012
ABA Section of Taxation Comments on Proposed Amendments to the Rules of the United States Tax Court
American Bar Association
March 1, 2012
Greece Payments: Smith & Nephew Settles Allegations of Corrupt Payments to Greek Surgeons
Ethisphere
February 22, 2012
Before It's Too Late: Reconsidering The IRS Relief for Madoff Losses
Tax Notes
February 20, 2012
Hedge Fund Managers Beware: Unless Claims are Assigned, Managers Do Not Have Standing to Sue for Their Funds
Bloomberg Law
February 15, 2012
No Time Like the Present for Gifting: Tax Relief Act Planning Opportunities
Advisory
February 8, 2012
Protecting Yourself and Your Client in a Joint Defense Arrangement
ABA Section of Taxation News Quarterly
February 1, 2012
Commissionaire and Contract Manufacturing Arrangements - New Developments on Permanent Establishment Issue
Corporate Taxation
January 1, 2012
Planning for Co-Investments Between a Private Foundation and a Disqualified Person
Journal of Taxation, Vol. 116, No. 1
January 1, 2012
Guidance From the IRS: The Logjam Finally Breaks
Estate Planning Magazine
December 1, 2011
Offshore Tax Enforcement, Voluntary Disclosure, And Undeclared Foreign Accounts
ALI-ABA Estate Planning Course Materials Journal
December 1, 2011
The Federal Estate and Gift Tax: A Case Study in Uncertainty
National Tax Journal
December 1, 2011
Israel: A Strategic Asset for the United States
The Jerusalem Post
November 8, 2011
The APA Program's Experience With Rev. Proc. 2008-31: Increased Opportunities for Certainty
Bloomberg BNA Tax Management Memorandum
November 7, 2011
Taxation of Passive Foreign Investment Companies: Current Rules, Problems and Possible Solutions
Corporate Taxation
November 1, 2011
The Case for Tradable Tax Credits
8 N.Y.U. J.L. & BUS. 227
November 1, 2011
2010 Treaty Developments
Corporate Taxation
November 1, 2011
OVDI Is Over — What's Next for Voluntary Disclosures?
Tax Notes, Special Report
October 17, 2011
Qualified Intermediaries, The EU Savings Directive, Trace--What Does FATCA Really Add
Corporate Taxation
September 1, 2011
Business, Values, and Law: Forging a New Dialogue
Georgetown University, Berkley Center for Religion, Peace & World Affairs
August 30, 2011
Unreported Gifts of Real Property: Time for a Voluntary Disclosure?
Tax Notes
August 1, 2011
Making Their Mark: The Supreme Court Clarified and Reshaped Class Action Law in the October 2010 Term
Mondaq
August 1, 2011
India's Proposed Direct Taxes Code - Highlights For Corporate Taxpayers
Corporate Taxation
July 1, 2011
Social Media at Work: Defining New Legal Boundaries
Rural Telecom
July 1, 2011
United States Supreme Court Holds That Loss Causation Is Not Required to Obtain Class Certification in a Securities Class Action
Mondaq
June 13, 2011
Crawford's Last Stand? What Melendez-Diaz v. Massachusetts Means for the Confrontation Clause and for Criminal Trials
2 AKRON J. CONST. L. & POL'Y 81
June 2, 2011
Finally Legislation! Congress Kicks the Can Down the Road
Estate Planning Magazine
May 31, 2011
FATCA & Foreign Bank Accounts: Has the U.S. Overreacted?
Tax Analysts
May 31, 2011
Final Rules & New FBAR Form Issued
International Tax Review
May 1, 2011
ITPF - Georgetown University Law Center Conference on Reform of International Tax
Corporate Taxation
May 1, 2011
Supreme Court Holds that Agreements with Arbitration Clauses Can Properly Waive Class Action Rights
Caplin & Drysdale
April 29, 2011
An Overview of the Foreign Account Tax Compliance Act
American Bar Association, 22nd Annual Spring Symposia
April 28, 2011
Short Cuts for Small Fry: Why the IRS Should Reconsider
BNA Tax Management-Transfer Pricing Report
April 21, 2011
IRS Seeks Names of U.S. Account Holders at HSBC (India)
Taxmann-The Tax & Corporate laws of India-International Tax
April 18, 2011
Comments to the Proposed Amendments to the Rules of the United States Tax Court
American Bar Association
March 7, 2011
Comments to the Proposed Amendments to the Rules of the United States Tax Court
American Bar Association
March 7, 2011
Putting an End to Foreign Tax Credit 'Splitting' Transactions
Corporate Taxation
March 1, 2011
ABA Section of Taxation Comments on Proposed Amendments to the Rules of the United States Tax Court
American Bar Association
March 1, 2011
United States: Decoding Cross-Border Tax Compliance: CFCs, PFICs, Foreign Trusts & Foreign Gifts And Bequest
Mondaq Business Briefing
March 1, 2011
Indictment of Offshore Account Holder Portends a New Round of Aggressive Enforcement
International Taxation
February 1, 2011
Effectively Representing Your Client Before the IRS
American Bar Association
January 3, 2011
U.S. Federal Tax Research
Tax Management Portfolio Series
January 3, 2011
Responsible Person and Lender Liability for Trust Fund Taxes – Sections 6672 and 3505
Tax Management Portfolio Series
January 3, 2011
Federal Campaign Finance Law: A Primer for the Lobbyist
ABA Lobbying Manual
January 3, 2011
President Obama's Efforts at International Tax Reform
Corporate Taxation
January 1, 2011
Advertising Liability: A Growing Risk Management Concern
Risk Management Handbook for Health Care Organizations
January 1, 2011
To Tweet or Not to Tweet: Twitter, Broadcasting, and Federal Rule of Criminal Procedure 53
Comment, 79 U. Cin. L. Rev. 769
January 1, 2011
The First Shoe Drops: Notice 2010-92 Provides Guidance on Section 909's Application to Pre-2011 Taxes
14 Practical International Tax Strategies
December 15, 2010
The Foreign Account Tax Compliance Act and Notice 2010-60
International Taxation
December 1, 2010
Happy New Year: Out with the Old, and in with the...Older!
Estate Planning Magazine
December 1, 2010
New Foreign Tax Credit Anti-Splitting Rule
Tax Notes
November 8, 2010
Executive Compensation Plans
Bloomberg Law Reports
November 8, 2010
Evolving Fiduciary Duties in the Era of Financial Reform
September 22, 2010
IRS's Voluntary Disclosure Program for Offshore Accounts: A Critical Assessment After One Year
BNA Insights
September 21, 2010
Tax Court Rules That UK Windfall Tax Is Creditable in the United States
International Law Office
September 17, 2010
Advise Client Companies to Review Payroll Practices
Verizon Small Business Center's News & Resources
September 10, 2010
Federal and State Governments Target Employment Tax Compliance
Taxation of Exempts
September 1, 2010
Four Common IRS Church Audit Issues
ECFA Focus On Accountability
August 24, 2010
Foreign Flow-Through Election’s Effect on Noncompulsory Tax Treatment
Tax Notes International
July 19, 2010
A Shift Toward Consumption Taxes: The Tax Policy Prescription For The Fiscal Ills of The Global Financial Crisis
Corporate Taxation
July 1, 2010
Using Subsidiaries to Hold and Manage Real Property
Taxation of Exempts
July 1, 2010
Utah's Way of Picking Candidates Robs Voters
The Salt Lake Tribune
June 21, 2010
Once Again Employment Tax Compliance at the Forefront of IRS's Enforcement Agenda
Bloomberg Law Reports
June 21, 2010
Virginia Is for Lovers and Fraudsters
June 3, 2010
The Foreign Account Tax Compliance Act
May 11, 2010
Loan Guarantees and Transfer Pricing
Corporate Taxation
May 1, 2010
2010: The Anatomy of a Train Wreck
Estate Planning Magazine
May 1, 2010
IRS Scrutinizes Payroll Practices, Challenges for Companies
Financial Executive
May 1, 2010
When Diversity Meets the Global Market: Forging a New Generation of Business Leaders
Georgetown University, Berkley Center for Religion, Peace & World Affairs
April 30, 2010
Taxpayer Wins LILO Case in the Court of Federal Claims
Real Estate Finance Journal
April 1, 2010
The New Battle In An Old War: Omissions From Gross Income
126 Tax Notes 1227
March 8, 2010
IRS Scrutiny of Equity Swaps Could Impact Offshore Funds
March 5, 2010
National Westminster Bank: Will the IRS Ever Give Up
Corporate Taxation
March 1, 2010
Federal Estate and GST Tax Repeal
Advisory
January 19, 2010
Estate Tax Expires - for Now
Washington Jewish Week
January 7, 2010
The Conservative Case for College Football Reform
The Hill
January 6, 2010
The Curious Case of The Partial Loophole Closer
Corporate Taxation
January 1, 2010
Kiva Dunes and Golf Course Conservation Easements: Important Implications for Tax Deductibility of Conservation Easement Contributions
Free State Accountant
January 1, 2010
Corporate Criminal Defense: Compliance, Investigation and Trial Strategies," Unique Procedures and Considerations in Tax Cases
Client Alert
January 1, 2010
Elections: Administrative Law Developments
American Bar Association
January 1, 2010
Budget and Health Care and Taxes. Oh My!
Estate Planning Magazine
December 1, 2009
Undeclared Foreign Accounts—Voluntary Disclosures and FBARs After the IRS Settlement Initiative
Journal of Tax Practice and Procedure
December 1, 2009
2009 Treaty Developments
Corporate Taxation
November 1, 2009
What Will Healthcare Legislation Hold for Nonprofit Hospitals?
Taxation of Exempts
November 1, 2009
The Final State of Expatriation? - Part I
Mondaq Business Briefing
October 1, 2009
The Final State of Expatriation? - Part II
Mondaq Business Briefing
September 28, 2009
Congress Can Better Voter Registration
Roll Call
September 14, 2009
Money Business: Constitutional Opinions
The American Spectator
September 11, 2009
Summary of Recent Developments for 2009
American Bar Association Section of Taxation, Court Procedure & Practice Committee
September 1, 2009
The New U.S.-Italy Treaty: A U.S. Perspective
Diritto e Pratica Tributaria Internazionale
August 1, 2009
Sotomayor Record Indicates Penchant for Protectionist State Tax Policies
Tax Foundation
July 16, 2009
Estate Tax Legislation in 2009: Avoiding the Train Wreck
Estate Planning Magazine
July 1, 2009
A New Page for Voting: It's Time to Ditch Paper-Based Registration
Washington Post
June 25, 2009
Addressing the Economic Downturn Under Existing Transfer Pricing Methods
Tax Notes International
June 22, 2009
Writing an Effective Corporate Political Activity Policy
Political Activity Law Bulletin
June 11, 2009
White House Revises Ban on Stimulus Contacts
Political Activity Law Bulletin
June 11, 2009
Hiring Former Federal Government Employees as Lobbyists
Political Activity Law Bulletin
June 11, 2009
New Guidance on Lobbyist Reporting and Termination
Political Activity Law Bulletin
June 11, 2009
SEC to Propose Pay-to-Play Rule for Investment Advisors in July
Political Activity Law Bulletin
June 11, 2009
Analysis of Bill Clinton's Cybersquatting Loss
Election Law Blog
June 4, 2009
Justice Souter's Tax Opinions Show Steady Erosion of Respect for Commerce Clause
Tax Foundation Fiscal Facts, No. 173
June 3, 2009
Private Foundations and the Protection of Assets
Tax Analysts, Special Report
June 1, 2009
Senior Lawyer Mortimer Caplin Receives Two Prestigious Awards
Senior Lawyer News
June 1, 2009
Comments to the Proposed Amendments to the Rules of the United States Tax Court
American Bar Association
May 27, 2009
Comments to the Proposed Amendments to the Rules of the United States Tax Court
American Bar Association
May 27, 2009
Resolución de Conflictos en Material Fiscal (in Spanish)
Revista - Instituto Colombiano de Derecho Tributario
May 10, 2009
Selected Recent Developments in Administrative Practice
American Bar Association (May Meeting, Administrative Practice Committee)
May 8, 2009
Next Phase of Election Reform: Start with Facts
Roll Call
May 5, 2009
Survival Techniques: Transfer Pricing in a Sick Economy
The Tax Executive
May 1, 2009
".Pol", a ".Com" for Political Candidates
CircleID
May 1, 2009
Time for a Change: Toward a New Korea-U.S. Income Tax Treaty
Tax Notes International
April 20, 2009
Shooting for the Stars
WebCPA
April 20, 2009
A Dot-Pol of Their Own
The Washington Post
April 11, 2009
Two Birds, One Stone: Reversing "Frontloading" by Fixing the Presidential Public Funding System
Virginia Journal of Law and Politics
April 9, 2009
GAO Report on Lobbying Disclosure
Political Activity Law Alert: Important Recent Developments
April 6, 2009
From the House that Ruth Built to the House the IRS Built
Tax Foundation Fiscal Facts, No. 167
April 6, 2009
Cross-Border Information Reporting & Civil Penalities (in a Nutshell)
Journal of Tax Practice & Procedure
April 1, 2009
States Use Gentle Hand in Taxing Timberland
Tax Foundation Fiscal Facts, No. 164
March 25, 2009
IRS Releases Hospital Report: Response from Capitol Hill
March 12, 2009
The Legal Framework for Not-for-Profit Organizations in Central and Eastern Europe
11 Int'l J. Not-for-Profit Law
February 1, 2009
Disclosure Rules for Lobbyist Bundling
Political Activity Law Bulletin
January 16, 2009
Gift Rules Applicable to Members and Staff of the 111th Congress
Political Activity Law Bulletin
January 16, 2009
Recent Developments in State Pay-to-Play Law
Political Activity Law Bulletin
January 16, 2009
Lobbyist Bundling of Campaign Contributions
ABA Lobbying Manuel
January 1, 2009
Candidates, Squatters and Gripers: A Primer on Political Cybersquatting and A Proposal for Reform
Election Law Journal
January 1, 2009
Information Reporting and Civil Penalties (In a Nutshell)
December 22, 2008
Wealth Transfer Strategies for Turbulent Times
Advisory
December 9, 2008
Voluntary Disclosure Key to Addressing Offshore Tax Cheats, Practitioners Say
Tax Analysts
December 8, 2008
Checking in with the Guidance Department
Estate Planning Magazine
December 1, 2008
Charities and Governance: Is the IRS Subject to Challenge?
Tax Analysts
November 18, 2008
A $200,000 Penalty for a $25,000 Deduction??!!: the High Price of Failing to Disclose Listed Transactions Under Section 6707A of the Code
November 7, 2008
The IRS Spotlight on Foreign Athletes and Entertainers
Mondaq Business Briefing
November 7, 2008
Foreign Trusts: Everything You Wanted to Know About the Taxation of Foreign Trusts But Were Afraid to Ask
MICPEL, Beyond QDOTs: International Estate Planning for a Flat World
October 23, 2008
A Model to Celebrate
OECD Observer
October 1, 2008
IRS Issues Revised Foreign Account Reporting Form
Tax Analysts
October 1, 2008
From Intent to Outcome: Balloting and Tabulation Around the World
ABA International Election Law Principles
October 1, 2008
Credit Default Swaps & the Bankrupt Counterparty - Entering the Undiscovered Country
Mondaq
September 25, 2008
In Praise of the OECD Model Tax Treaty
Worldwide Tax Daily
September 23, 2008
Separating Exempt-Purpose & Non-Exempt-Purpose Activities
Taxation of Exempts
September 17, 2008
Sound and Fury, Signifying What? The U.S. Foreign Earned Income Exclusion Debate
Tax Notes International
September 15, 2008
Summary of Recent Developments for 2008
American Bar Association Section of Taxation, Court Procedure & Practice Committee
September 1, 2008
Voodoo Economics: A Look Abroad for a Supply-Side Solution to America's Campaign Finance Riddle
Vanderbilt Journal of Transnational Law
September 1, 2008
From Arbitration to Zero Withholding: A Primer on the U.S.-Canada Treaty Protocol
Tax Notes International
August 20, 2008
The Malpractice Environment for Tax Lawyers in the United States
Practice Exposures for the International Tax Professional in the 21st Century, 37 Tax Management International Journal 431
August 8, 2008
The IRS’s New Whistleblower Program – Another Enforcement Alert for International Business
July 24, 2008
The Current State of Expatriation
Guide to International Estate Planning, American Bar Association
June 3, 2008
Hearing It Out
Estate Planning
June 1, 2008
Conservation Easements Under Fire: A Five-Point Strategy to Defend the Deduction
Maryland Society of Accountants: The Free State Accountant
June 1, 2008
Coming Full Circle? Secondary Adjustments and Repatriation in Transfer Pricing Cases
Tax Management Transfer Pricing Report, Bloomberg BNA
May 1, 2008
Voluntary Disclosure Becomes A Necessity
International Tax Review
May 1, 2008
Curing Non-Compliance: Practical Factors to Consider in the United States
International Bar Association, International Wealth Transfer Pricing Conference
March 3, 2008
Deductions for Non-U.S. Persons Under U.S. Income Tax Laws
International Tax Planning
March 1, 2008
Tax Crimes: Has the Bright Line Moved?
Law Journal Newsletters
February 1, 2008
Federal Tax Laws Affecting Political Activity and Lobbying by Tax-Exempt Charitable Organizations
Political Activity, Lobbying Laws and Gift Rules Guide
January 1, 2008
Political Activity, Lobbying Laws and Gift Rules Guide (Book)
West Publishing (Third Edition, Second Edition 1999)
January 1, 2008
Money Adds New Dimension to 'Veepstakes'
The Politico
December 5, 2007
'Prior Work' Can Create Ethical and Malpractice Risk
ABA Section of Taxation NewsQuarterly
December 1, 2007
Gazing Into the Crystal Ball: A Prediction of Post-Election Action
Estate Planning Magazine
December 1, 2007
The Practical Impact of FIN48 - Is it Moving Abroad?
November 1, 2007
IRS Sends Mixed Messages to Nonprofis
POLITICO
October 16, 2007
Developments Aplenty in the KPMG Tax Case: Partial Dismissal, and Court-Ordered Transparency In Entity/Government Negotiations
September 30, 2007
Treasury, IRS Continues Attack on Abusive Tax Transactions: Final Regulations for Reportable Transactions Issued
Derivatives Financial Products Report
September 1, 2007
Self-Created Transfer Pricing Adjustments
Tax Notes International
June 4, 2007
Legislative Paralysis
June 1, 2007
Supporting Organization Provisions Of The Pension Protection Act Of 2006
ALI-ABA Estate Planning Course Materials Journal
June 1, 2007
COMMENT: Deputy-Doctors: The Medical Treatment Exception after Davis v. Washington
43 CAL. W. L. REV. 451, 2007
May 1, 2007
Tax Alert
Caplin & Drysdale
May 1, 2007
Meeting Newsletter
American Bar Association Section of Taxation, Court Procedure & Practice Committee (2006-2007)
May 1, 2007
ABA's Comments Concerning the Tax Court's Proposed Amendments Regarding Privacy and Public Access to Electronic Case Files
American Bar Association
April 13, 2007
Blame It on Transparency
Tax Notes
March 5, 2007
Last-Minute Changes and Partial Delays Under New Intercompany Service Rules
Caplin & Drysdale
February 1, 2007
Cono R. Namorato Sets the Record Straight for Corporate Tax Counsel & Corporate Tax Directors
Caplin & Drysdale
February 1, 2007
Charitable Giving Incentives and Reforms in the Pension Protection Act
Taxation of Exempts
January 1, 2007
Pay Immediate Attention to Far-Reaching Regulations on Intercompany Services
Caplin & Drysdale
October 1, 2006
Play it Again Sam – The IRS (More or Less) Finishes the Section 482 Services Regulations
The Tax Executive
October 1, 2006
New Penalties for Tax-Exempt Entities and Managers
Caplin & Drysdale
October 1, 2006
Thou Shalt Not Profit, Part I: New Penalties for Tax-Exempt Entities and Managers
Health Lawyers Weekly
September 8, 2006
D.C. Circuit Extends Supreme Court's Interpretation of 'Derivative Use' Under 'Act of Production' Immunity
Andrews Litigation Reporter: White Collar Crime
September 1, 2006
Tax Alert
Caplin & Drysdale
May 1, 2006
Proposed Cost-Sharing Regulations Issued
Practical US/Domestic Tax Strategies
May 1, 2006
A Rare Look Inside The IRS's Office of Professional Responsibility
Journal Of Tax Practice and Procedure
May 1, 2006
Deferred Prosecution Agreements: Implications for Corporate Tax Departments
The Tax Executive
February 1, 2006
IRS Launches Settlement Initiative for Certain "Abusive Transactions"
Caplin & Drysdale
January 15, 2006
Proposed Cost-Sharing Regulations Issues
Caplin & Drysdale
January 15, 2006
A New Age in Cost Sharing? The IRS Proposed Regulations
Tax Management International Journal
December 9, 2005
Tax Planning for Involuntary Conversions
Tax Notes
October 3, 2005
August 2005
Re:Cap
August 31, 2005
Revisiting the Hospital Admissions Agreement in Light of the State Charity-Care Litigation
Health Lawyers Weekly
August 26, 2005
Enhanced IRS Enforcement and the Voluntary Disclosure Policy
International Law Office
August 26, 2005
I'll Pay, but Let's Not Call It a Fine: Code Sec. 162(f) Issues in Structuring Settlement Payments - Five Lessons from LTR 200520241
Taxes - The Tax Magazine
July 5, 2005
Tax Alert
Caplin & Drysdale
June 15, 2005
May 2005
Re:Cap
May 15, 2005
The Law of Unintended Consequences: International Implications of Section 409A
The Tax Executive
April 1, 2005
April 2005
Re:Cap
April 1, 2005
March 2005
Re:Cap
March 1, 2005
Tax Alert
Caplin & Drysdale
February 1, 2005
Tsunami: NGO's Response: Now and the Future
47 Exempt Organizations Tax Review 181
February 1, 2005
February 2005
Re:Cap
February 1, 2005
The New Campaign Finance Sourcebook
Brookings Institution
January 1, 2005
The Delegation of Investment Authority by Nonprofit Corporate Boards Under UMIFA
Taxation of Exempts
January 1, 2005
Speech Governed by Federal Election Laws and Election Law and the Internet
The New Campaign Finance Sourcebook, The Brookings Institution
January 1, 2005
Technology Transfer and the New Economy
The Exempt Organization Tax Review
January 1, 2005
January 2005
Re:Cap
January 1, 2005
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
January 1, 2005
The IRS Office of Professional Responsibility
Business Crime Bulletin
December 1, 2004
Criminal Tax Investigations and Current Year Returns: New Thoughts on a Perennial Issue
White Collar Crime Reporter (v. 19, Issue 3)
December 1, 2004
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
December 1, 2004
December 2004
Re:Cap
December 1, 2004
November 2004
Re:Cap
November 10, 2004
Tax Shelter Reform
Caplin & Drysdale
November 1, 2004
October 2004
Re:Cap
October 1, 2004
Stop the Presses (Book Review)
Law Practice Magazine
September 1, 2004
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
September 1, 2004
Politics and the Pulpit
Tax Notes
September 1, 2004
Playing by the Rules
Caplin & Drysdale
September 1, 2004
September 2004
Re:Cap
September 1, 2004
U.S. Issues Guidance on Apportionment of Charitable Contributions to U.S.-Source Income
Tax Notes International
August 9, 2004
Russia: A "Virtual" Democracy
The Exempt Organization Tax Review
August 1, 2004
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
August 1, 2004
Foreign Bank Accounts - Last Chance for Taxpayers?
Caplin & Drysdale
July 1, 2004
News on the Transfer Pricing Front
Caplin & Drysdale
July 1, 2004
June 2004
Re:Cap
June 16, 2004
But I Don't Sell Tax Shelters! The Expanding Reach of the Code Sec. 6700 Promoter Penalty
Taxes - The Tax Magazine
June 1, 2004
TNI Interview: H. David Rosenbloom
Tax Notes International
May 10, 2004
How Safe is Taxpayer Information in the Hands of Congress
Caplin & Drysdale
April 1, 2004
The Impact of the Bipartisan Campaign Reform Act on Tax Exempt Organizations Still Evolving
Caplin & Drysdale
April 1, 2004
Section 6700 - IRS's Newly Found Weapon Against Professionals
Caplin & Drysdale
April 1, 2004
April 2004
Re:Cap
April 1, 2004
Banes of an Income Tax: Legal Fictions, Elections, Hypothetical Determinations, Related Party Debt*
The Sydney Law Review
March 30, 2004
Think About Subpart F: The Domestic Base Company
The Tax Magazine
March 15, 2004
March 2004
Re:Cap
March 1, 2004
India: Great Potential and Promise
The Exempt Organization Tax Review
February 25, 2004
February 2004
Re:Cap
February 1, 2004
The United States Law of Charities: A Summary
China Society Press
January 1, 2004
January 2004
Re:Cap
January 1, 2004
Banes of an Income Tax: Legal Fictions, Elections, Hypothetical Determinations, And Related Party Debt
Tax Notes International
December 31, 2003
Why Not Des Moines? A Fresh Entry in the Subpart F Debate
Tax Notes International
December 15, 2003
The Final Word on Stock Options in Cost Sharing Arrangements?
Tax Management International Journal
December 1, 2003
Corporate Tax Departments and the New Focus on Corporate Criminality
The Tax Executive
December 1, 2003
December 2003
Re:Cap
December 1, 2003
Markers and Musings: The Proposed Section 482 Service Regulations
The Tax Executive
December 1, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
November 30, 2003
Recent Developments in the Tax Shelter Area
Caplin & Drysdale
November 1, 2003
"Hot Interest" for Large Corporate Underpayments
Caplin & Drysdale
November 1, 2003
Transfer Pricing: New Rules for Services and Intangibles
Caplin & Drysdale
November 1, 2003
November 2003
Re:Cap
November 1, 2003
An Awakening Giant: China and the New Civil Society
The Exempt Organization Tax Review
October 1, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
October 1, 2003
October 2003
Re:Cap
October 1, 2003
Russia in Transition
The Exempt Organization Tax Review
September 30, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
September 1, 2003
September 2003
Re:Cap
September 1, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
August 1, 2003
August 2003
Re:Cap
August 1, 2003
Testimony of David Rosenbloom Before the U.S. Senate Committee on Finance
Committee on Finance, United States Senate
July 15, 2003
July 2003
Re:Cap
July 1, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
July 1, 2003
If I Had a Hammer
Legal Times
June 9, 2003
June 2003
Re:Cap
June 1, 2003
Codification of Economic Substance
Caplin & Drysdale Memorandum
May 7, 2003
May 2003
Re:Cap
May 1, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
May 1, 2003
Transfer Pricing: IRS Cracking Down on Transfer Pricing Compliance
Caplin & Drysdale
April 1, 2003
Tax Accoutning: Proposed Capitalization Regulations - Not All Good News
Caplin & Drysdale
April 1, 2003
Tax Shelters: Treasury Finalizes Tax Shelter Reporting Regulations
Caplin & Drysdale
April 1, 2003
Corporate Taxation: New Consolidated Return Duplicated Loss Rules
Caplin & Drysdale
April 1, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
April 1, 2003
April 2003
Re:Cap
April 1, 2003
March 2003
Re:Cap
March 1, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
March 1, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
February 1, 2003
February 2003
Re:Cap
February 1, 2003
Tax Advice After Sarbanes-Oxley
Caplin & Drysdale Tax Advice
January 24, 2003
Election Law and the Internet
The Civic Web, Rowan & Littlefield Publishers, Inc.
January 1, 2003
January 2003
Re:Cap
January 1, 2003
Donor Intent: Preserving the Mission of Charitable Foundations
Washington Legal Foundation (www.wlf.org)
January 1, 2003
Taxpayer Privacy and Disclosure Issues Will Continue to Touch Us All
The Future of American Taxation (Tax Analysts)
December 1, 2002
December 2002
Re:Cap
December 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
December 1, 2002
Option Wars: Upping the Ante for Cost Sharing Arrangements
Tax Management International Journal
November 8, 2002
November 2002
Re:Cap
November 1, 2002
The Tax Court Decides the Opening Skirmish in Intermediate Sanctions Litigation
Taxation of Exempts
November 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
November 1, 2002
October 2002
Re:Cap
October 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
October 1, 2002
Accounting Methods - Which Retroactive 'Corrections' Require IRS Consent?
Tax Lawyer, Vol. 56, No. 101
September 1, 2002
Second First?? Transfer Pricing Issues In Secondment of Personnel
The Tax Executive
September 1, 2002
September 2002
Re:Cap
September 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
September 1, 2002
Treasury Department Closing the Door on Tax Shelters
Washington Business Journal
August 5, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
August 1, 2002
August 2002
Re:Cap
August 1, 2002
The Viability of Multidisciplinary Practice
The Insurance Tax Review
August 1, 2002
Letter Ruling Alert: A Blueprint for Creating a Taxable Subsidiary
The Exempt Organization Tax Review
August 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
July 1, 2002
The Importance of Transparency: A Review of the Public Disclosure Rules
Focus on Accountability
July 1, 2002
July 2002
Re:Cap
July 1, 2002
Of Merchandise, Accruals, And Administrative Grace
Tax Notes
June 17, 2002
June 2002
Re:Cap
June 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
June 1, 2002
The Viability of Multidisciplinary Practice
The Washington Lawyer
May 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
May 1, 2002
May 2002
Re:Cap
May 1, 2002
Recent Developments in Treasury's Campaign Against Tax Shelters
Caplin & Drysdale
April 12, 2002
Evaluating and Managing Tax Shelter Risks
Caplin & Drysdale
April 12, 2002
April 2002
Re:Cap
April 1, 2002
Deconstructing Section 905(c): An Examination of The Redetermination Rules After TRA 1997
Tax Notes International
April 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
April 1, 2002
March 2002
Re:Cap
March 1, 2002
IRS Form 990 Donor Disclosure
The Exempt Organization Tax Review
March 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
March 1, 2002
Taxes Covered By §960(a)(3)
Tax Management International Journal
February 8, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
February 1, 2002
Disaster Relief Activities of Charitable Organizations
The Exempt Organization Tax Review
February 1, 2002
February 2002
Re:Cap
February 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
January 1, 2002
January 2002
Re:Cap
January 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
December 1, 2001
Letter Ruling Alert: A New Twist in Donations of Stock Options By Disqualified Persons
The Exempt Organization Tax Review
December 1, 2001
December 2001
Re:Cap
December 1, 2001
The Tax Consequences of Accepting Charitable Contributions Through a Single-Member LLC
Taxation of Exempts
November 1, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
November 1, 2001
November 2001
Re:Cap
November 1, 2001
Letter Ruling Alert: Round Income, Square Tax Code
The Exempt Organization Tax Review
November 1, 2001
October 2001
Re:Cap
October 1, 2001
Tax Accounting Montly Column
Corporate Business Taxation Monthly
October 1, 2001
Letter Ruling Alert: PRI Possibilities in the Age of Venture Philanthropy: Foundation's Investment in Environmental Venture-Capital Fund Qualifies as a Program-Related Investment
The Exempt Organization Tax Review
October 1, 2001
The State of Lawyering
Senior Lawyer News
September 1, 2001
Letter Ruling Alert: Service Excludes Ministers' Housing Allowances from Compensation for Purposes of Determining Retirement Plan Contribution Limits
The Exempt Organization Tax Review
September 1, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
September 1, 2001
From the Bottom Up: Taxing the Income of Foreign Controlled Corporations
Brooklyn Journal of International Law
September 1, 2001
September 2001
Re:Cap
September 1, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
August 1, 2001
Exempt Organizations Tax Update
The Exempt Organization Tax Review
August 1, 2001
August 2001
Re:Cap
August 1, 2001
Estate, Gift, and Generation-Skipping Taxes: The Implications of the Economic Growth and Tax Relief Reconciliation Act of 2001
Caplin & Drysdale
July 11, 2001
Contingent Fees and Tort Reform: A Reassessment and Reality Check
Law and Contemporary Problems
July 1, 2001
Income Tax Changes, Estate Tax Changes And Implications for Charitable Giving Of the Economic Growth and Tax Relief Reconciliation Act of 2001
Caplin & Drysdale
July 1, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
July 1, 2001
July 2001
Re:Cap
July 1, 2001
June 2001
Re:Cap
June 1, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
June 1, 2001
'If Americans Really Understood The Income Tax'
Tax Notes
May 28, 2001
The IRS Reorganization: Programs and Initiatives of the New Large Case Division
Administrative Law Review, Vol. 53, No. 2
May 1, 2001
May 2001
Re:Cap
May 1, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
May 1, 2001
President Bush Presents His Tax Plans for Charitable Giving
Journal of Taxation of Exempt Organizations
May 1, 2001
April 2001
Re:Cap
April 1, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
April 1, 2001
Caplin Calls for Fairness and Simplification in New Tax Legislation
Tax Notes
March 5, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
March 1, 2001
Tax-Exempt Organizations and the Internet: Tax and Other Legal Issues
The Exempt Organization Tax Review
March 1, 2001
Now Is the Time to Reform the Tax Code
The Wall Street Journal
February 7, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
February 1, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
January 1, 2001
Letter Ruling Alert: Charities and Election-Year Politics - The Transformation of a Public Figure's Charity Fund-Raising Letter into a Charity-Sponsored Campaign Advertisement
The Exempt Organization Tax Review
December 1, 2000
Teaching Taxation: Following the Money in the 2000 Election
The Exempt Organization Tax Review
December 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
December 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
November 1, 2000
Letter Ruling Alert: Shades of Revenue Ruling 98-15 - Ancillary Joint Ventures Between Tax-Exempt Organizations and For-Profit Entities
Exempt Organization Tax Review
November 1, 2000
Congress Requires Disclosure by Section 527 Organizations
Journal of Taxation of Exempt Organizations
November 1, 2000
The Disclosure Debate Rages On … And On
89 Tax Notes 419
October 16, 2000
Important Points to Remember: The Disclosure Debate
89 Tax Notes 301
October 9, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
October 1, 2000
Arbitrage and Transfer Pricing Paper
Report of Proceedings of the First World Tax Conference: Taxes Without Borders
October 1, 2000
Issue Advocacy: If It Cannot Be Regulated When It Is Least Valuable, It Cannot Be Regulated When It Is Most Valuable
Catholic University Law Review
September 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
September 1, 2000
Cost-Sharing Arrangements Come of Age
Tax Management Memorandum
August 28, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
August 1, 2000
Transfer Pricing: A Special Report
International Tax Review Supp. 31
July 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
July 1, 2000
Tax-Exempt Bond Issuers Should Welcome an Excise Tax
21-2 Municipal Finance Journal 55
June 1, 2000
The UPS, Limited and Compaq Cases: Is the Tide Turning?
26 International Tax J. No. 3, 1
June 1, 2000
Tax Workouts and Procedures During and After the IRS Restructuring
Virginia Conference on Federal Taxation
June 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
June 1, 2000
Weighing the Alternatives to Private Foundations
Journal of Taxation of Exempt Organizations
May 1, 2000
Mining For Nuggets in the IRS APA Report
The Tax Executive
May 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
May 1, 2000
Tax-Exempt Organizations and the Internet (Part 2)
The Practical Tax Lawyer
April 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
April 1, 2000
Transfer Pricing Thoughts - North America: More Thoughts On APA Disclosure
Global Transfer Pricing
March 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
March 1, 2000
A New Way to Resolve a Factual Issue with the IRS Before Filing a Return
Caplin & Drysdale
February 21, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
February 1, 2000
Bob Jones Revisited
EO Tax Journal
February 1, 2000
Treaties and Interest Expense Allocation: Moving in a Natwesterly Direction
Tax Notes
January 17, 2000
Federal Election Law and the Internet
Brookings Institution
January 1, 2000
The 1969 Private Foundation Law: Historical Perspective on its Origins and Underpinnings
Exempt Organization Tax Review
January 1, 2000
Tax-Exempt Organizations and the Internet (Part 1)
The Practical Tax Lawyer
January 1, 2000
Foreign Income Portfolios: U.S. Income Taxation of Foreign Corporations
Tax Management
January 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
January 1, 2000
Private Foundation Grants to Public Charities Engaged in Advocacy on Environmental Issues
Exempt Organization Tax Review
December 2, 1999
Environmental Protection: The Relationship with Human Rights
Exempt Organization Tax Review
December 1, 1999
Tax Accounting Monthly Column: Bank's Loan Origination Costs Emerge As a High-Profile Issue
Corporate Business Taxation Monthly
December 1, 1999
Transfer Pricing Thoughts - North America: Thoughts on Code Sec. 482 and Rising Standards of Proof
Global Transfer Pricing
December 1, 1999
Letter Ruling Alert: A New Option for Private Foundation Investing
Exempt Organization Tax Review
November 1, 1999
Tax Accounting Monthly Column: Clear Reflection Principles May Work For Taxpayers Too
Corporate Business Taxation Monthly
November 1, 1999
Responses to the 'Lurking Marriage Penalty'
National Law Journal
October 4, 1999
Tax Accounting Monthly Column: IRS Wins Before the Tax Court in Norwest
Corporate Business Taxation Monthly
October 1, 1999
Transfer Pricing Thoughts - North America: Thoughts on Control
Global Transfer Pricing
October 1, 1999
At the Front--New Institute Propels Reform Efforts
Tax Notes International
September 27, 1999
Advising a Client with Secret Offshore Accounts - Current Filing and Reporting Problems
Journal of Taxation
September 1, 1999
Transfer Pricing Thoughts - North America: Thoughts on Cooperatives
Global Transfer Pricing
August 1, 1999
When Is Tax Practice 'Legal'?
Legal Times
July 5, 1999
Minimizing Risk and Maximizing Benefits Under the Final Disclosure Regs. For Exempt Organizations
Journal of Taxation
July 1, 1999
Transfer Pricing Thoughts - North America: Thoughts on APA Disclosure
Global Transfer Pricing
June 1, 1999
New Technologies in Retirement Plan Administration
Caplin & Drysdale Alert
May 4, 1999
Tax Court Rules (Again) on Sierra Club Affinity Card Income
Exempt Organization Tax Review
May 1, 1999
The "Ins" "Outs" "Overs" and "Unders" of the New Global Netting Rules
Tax Notes
April 26, 1999
Transfer Pricing Thoughts - North America: The Euro and the Situs of the Borrower Rule
Global Transfer Pricing
April 1, 1999
How the IRS Plans to Restructure Its Exempt Organization Operations
Journal of Taxation of Exempt Organizations
April 1, 1999
IRS Intermediate Sanctions: How They Will Impact Colleges and Universities
The Journal of College and University Law
April 1, 1999
Transfer Pricing Thoughts - North America: Thoughts on Joint Ventures
Global Transfer Pricing
February 1, 1999
Navigating the Global Netting Rules: Uncertainties Abound in Interest Rate Calculation Process Under New Law
Practical U.S. /International Tax Strategies
December 10, 1998
U.S. Proposed Global Trading Regs: Preliminary Questions Regarding Application
Tax Notes International
May 23, 1998
Commentary: Caplin & Drysdale Blasts Proposed Foreign Tax Credit Regs
Tax Notes International
May 5, 1997
Strategies for Filing a Tax Return While Under a Criminal Tax Investigation
Journal of Asset Protection
September 1, 1996
The Hamas Deportation: Israel's Response to Terrorism During the Middle East Peace Process
10 Am. U. J. Intl'l & Pol'y 397
January 1, 1994