Publications Archive

"Cui Bono Fuisset": Coordinating U.S. Tax Statutes with U.S. Tax Treaties
Article, Virginia Tax Review, 02.26.2021
IRS to "Campaign" into Puerto Rico; How can Taxpayers Defend?
Tax Alert, 02.03.2021
FEC Updates Contribution Limits for 2021-2022
Political Law Alert, 02.02.2021
Coke Concentrate: A Recipe for Understanding the IRS's Biggest Win in 40 Years
Article, IBFD International Transfer Pricing Journal, 01.28.2021
The Adams Challenge Tax Court Decision Reinforces the Benefits of Foreign Taxpayers Filing Protective U.S. Returns
Tax Alert, 01.26.2021
President Biden Signs Comprehensive New Executive Order on Executive Branch Personnel Ethics
Political Law Alert, 01.22.2021
IRS Releases Final Carried Interest Regulations
Business, Investment & Transactional Tax Alert, 01.14.2021
INSIGHT: The 2020 Revision to the Internal Revenue Manual's Voluntary Disclosure Practice: More Consistency with Greater Risk
Article, Bloomberg Tax: Daily Tax Report, 01.12.2021
The Electoral College Isn't Supposed to Work This Way
Article, New York Times Op-Ed, 01.06.2021
2021 Ushers in Decreased D.C. Estate Tax Exemption, Potential Additional Probate and Estate Tax Legislation
Private Client Alert, 01.05.2021
Are The IRS's New Terms Worth It
Article, Captive Review, 12.22.2020
No, Jan. 6 Isn't Another Chance for Trump to Reverse the Election
Article, The Washington Post Op-Ed, 12.17.2020
IRS Wins Big in The Coca-Cola Company & Subs. v. Commissioner
International Tax Alert, 11.23.2020
Trump's Legal Strategy is to Sue First and Ask Questions Later. That's Dangerous.
Article, The Washington Post Op-Ed, 11.13.2020
U.S. Tax Enforcement – A New Decade Begins
IFC, 11.05.2020
Reforming The FEC: Effective Commissioners Are Needed
Article, Law360 Op-Ed, 10.26.2020
Financier Worldwide Annual Review: Transfer Pricing 2020 – United States
Article, Financier Worldwide, 10.05.2020
Trump's Campaign Can Be Put on Hold. Election Day Can't.
Article, The Washington Post Op-Ed, 10.03.2020
IRS Kicks Off Post-Altera Audit Adjustments
Tax Alert, 09.21.2020
Inside the Proposed New York Privacy Act
Article, New York Journal , 09.20.2020
CFCs and the Individual Shareholder
Article, Tax Notes International, 09.14.2020
September 15th Deadline for Taxpayer Participation in North Carolina Transfer Pricing Resolution Initiative
State and Local Tax Alert, 08.24.2020
IRS Issues Proposed Carried Interest Regulations
Business, Investment & Transactional Tax Alert, 08.19.2020
Treasury Finalizes GILTI High-Tax Exclusion Rules
Tax Alert, 07.28.2020
The IRS Resumes its Global High-Wealth Examination Program and Targets High Income Non-Filers
Tax Alert, 07.22.2020
FDII Documentation Requirements Relaxed
International Tax Alert, 07.20.2020
Final FDII/GILTI Regulations Withdraw Deduction Ordering Rule
Business, Investment & Transactional Tax Alert, 07.20.2020
Challenge to the Constitutionality of the ACA Raises NII Tax Refund Possibility
Tax Alert, 07.06.2020
A Seat at the Table: Thought Leaders Discuss OECD's Plans on Digital Economy Taxation
Article, Tax Notes Federal, 06.15.2020
COVID-19 and Tax Law: A Current View from the United States
Article, Belt and Road Initiative Tax Journal, 06.03.2020
GST Exemption Allocation for 2019, Better Late than Timely
Article, Steve Leimberg's Estate Planning Email Newsletter, 05.20.2020
TAX PRACTICE: A Silver Linings Guidebook: Corporate Planning for Coronavirus Losses
Article, Tax Notes Federal, 05.18.2020
INSIGHT: The IRS's Renewed Focus on Fraud-Implications for Tax Practitioners
Article, Bloomberg Law, 05.08.2020
COVID-19 Government "Re-Open" Advisory Groups Often Subject to Lobbying and Ethics Rules
Political Law Alert, 05.06.2020
Timely Estate Planning Techniques, Including "May Day" GRATs
Private Client Alert, 04.30.2020
"May Day" GRATs: An Excellent Estate Planning Opportunity
Private Client Alert, 04.30.2020
IRS Proposes Regulations on UBTI Siloing; Comments Due Soon
Exempt Organizations Alert, 04.28.2020
IRS Will Continue Captive Insurance and Syndicated Conservation Easement Examinations Despite Covid-19 Pandemic
Tax Alert, 04.27.2020
UPDATE: Applying for Federal Tax-Exemption Under Section 501(c)(3)
Article, Practical Law, 04.23.2020
Damage Mitigation: The IRS Helps Alleviate Effect of COVID-19 on U.S. and Foreign Residency
Tax Alert, 04.22.2020
Growing List of States and Localities Extend Lobbying Filing Deadlines in Response to COVID-19 Pandemic
Political Law Alert, 04.16.2020
Partnership Filing Relief
Tax Alert, 04.13.2020
UPDATE: CARES Act Assistance for Nonprofit Employers: Retention Credits and Tax Deferral
Exempt Organizations Alert, 04.13.2020
Updated Filing and Payment Extensions Under Notice 2020-23
Tax Alert, 04.10.2020
CARES Act Assistance for Nonprofit Employers: Update on Loans to Larger Nonprofits
Exempt Organizations Alert, 04.10.2020
IRS Extends the Deadline for Exempt Organizations to File Federal Tax Returns
Exempt Organizations Alert, 04.10.2020
Businesses and Organizations Seeking Government Assistance in COVID-19 Crisis Should Pay Attention to "Procurement Lobbying" Rules
Political Law Alert, 04.06.2020
UPDATE: CARES Act Assistance for Nonprofit Employers: Paycheck Protection Loans and Loan Forgiveness
Exempt Organizations Alert, 04.03.2020
CARES Act Assistance for Nonprofit Employers: Loans, Emergency Grants and Other Assistance
Exempt Organizations Alert, 04.03.2020
Collateral Damage: Covid-19 and its Unintended Effect on U.S. Residency
Tax Alert, 04.01.2020

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