Publications Archive

Financier Worldwide Indepth Feature: Transfer Pricing 2023
Article, Financier Worldwide Magazine, 04.27.2023
Statute of Limitations Considerations Under the BBA
Article, Tax Notes Federal, 04.17.2023
Tax Court Rules that IRS Lacks Statutory Authority to Assess Penalties for Failure to File Form 5471
Tax Alert, 04.06.2023
Evaluating and Improving The Taxpayer Rights Provisions of the IRS Restructuring and Reform Act of 1998
Pittsburgh Tax Review, 03.16.2023
Defending Your Puerto Rico Source Income in an IRS Campaign Audit
International Tax Alert, 03.10.2023
All or Nothing: Defending Your Puerto Rico Bona Fide Residency Against an IRS Campaign Audit
International Tax Alert, 02.17.2023
FEC Updates Contribution Limits for 2023-2024
Political Law Alert, 02.02.2023
Preparing for Battle: The IRS Puerto Rico Campaign Takes Off
International Tax Alert, 02.01.2023
Financier Worldwide Roundtable: Transfer Pricing
Article, Financier Worldwide Magazine, 01.25.2023
Pillar One and Pillar Two: The Well-Intentioned (But Unfortunate) Pursuit of Perfection
Article, Belt and Road Initiative Tax Journal, 01.11.2023
Time for a Tax Treaty Timeout
Article, Tax Notes Today International , 01.03.2023
Entrepreneur or Hobbyist: Turning Losses Into a Win
Article, Practical Tax Strategies Thomson Reuters , 01.01.2023
IRS Takes Aim at Law Firms’ Deferred Payment Arrangements for Contingency Cases
Tax Alert, 12.28.2022
IRS Announces It Will Start Following the Law (With Respect to Identifying Some Listed Transactions)
Procedurally Taxing , 12.09.2022
IRS to Issue Proposed Regulations Identifying Syndicated Conservation Easements as Listed Transactions
Tax Alert, 12.07.2022
“Me? A ‘Foreign Agent?!’” Helping Clients Respond to FARA Administrative Investigations by the Department of Justice
Article, National Law Journal, 11.29.2022
What Do I Need to Know About the Corporate Transparency Act?
California Trusts and Estates Quarterly , 11.01.2022
VIEWPOINT: Transfer Pricing's Next Generation
Tax Notes Federal, 10.17.2022
California Implements New Changes to Lobbying and Campaign Finance Laws
Political Law Alert, 10.10.2022
Celebrating Leadership at the OECD
Article, Tax Notes International , 09.19.2022
Counterpoint: The IRS’s First-Time Abatement Policy . . . Even Harsher Than You Realized
Article, ABA Tax Times, 08.30.2022
IRS Grants Penalty Relief for Certain 2019 and 2020 Returns
Tax Alert, 08.25.2022
Inflation Reduction Act of 2022 Would Expand Scope of Carried Interest Rule
Business, Investment & Transactional Tax Alert, 08.03.2022
Where the Money Is: Tax and Worker Mobility
Article, Tax Notes International, 08.01.2022
FTCs and the 'Two-State Problem': Recognizing Contested Governments for Tax Purposes
Article, Tax Notes International , 07.02.2022
Supreme Court Overturns Roe v. Wade: What Does it Mean for Nonprofits?
Exempt Organizations Alert, 06.28.2022
Supreme Court Alert: Supreme Court Finds U.S. Trustee Fee Increase Unconstitutional
Alert, 06.24.2022
If the FEC Won’t Protect Voters, the Courts Should — But it Might Be Up to Congress
Article, The Hill, 06.17.2022
New FTC Regulations Could Mean Trade-Offs Between Creditable Foreign Taxes and Proliferation of Treaty Baskets
Article, International Tax Journal , 05.31.2022
Financier Worldwide Annual Review: Transfer Pricing 2022 – United States
Article, Financier Worldwide, 04.28.2022
VIEWPOINT: The Branch Rule: An Unhurried Read of the Statute
Article, Tax Notes International, 04.04.2022
Obtaining Refunds of Section 6707A and Section 6707 Penalties Paid for Not Properly Reporting Listed Transactions or Transactions of Interest (Including Notice 2007-83 and Notice 2016-66)
Tax Alert, 03.22.2022
Defined Contribution Plan Alert: IRS Proposes New Rules for Required Minimum Distributions
Employee Benefits Alert, 03.16.2022
Information Reporting Arbitrage: The New American Way
Article, IFC, 03.09.2022
What's the IRS Criminal Investigation Division Telling Us About Its Priorities and Update on the Erosion of the Attorney-Client Privilege in Tax Cases
Article, ABA White Collar Crime Committee Newsletter, 03.07.2022
The Enduring Value of Departures in a Post-Booker World
Article, ABA White Collar Crime Committee Newsletter, 03.07.2022
Taxpayer Defeats IRS Penalty in Tax Court for Conservation Easement Transaction
Tax Alert, 12.21.2021
Ready or Not, It's Time for Transparency FinCEN Proposes Rules to Implement Beneficial Ownership Reporting Requirements
International Tax Alert, 12.17.2021
Supreme Court Alert: Supreme Court Declines to Address the Viability of the Equitable Mootness Doctrine
Article, Lexology, 10.29.2021
VIEWPOINT Toulouse: No Treaty-Based Credit?
Article, Tax Notes International, 10.25.2021
Financier Worldwide Annual Review: Global Tax 2021 – United States
Article, Financier Worldwide, 10.25.2021
FARA: Issues and Recommendations for Reform
American Bar Association, International Law Section, 09.29.2021
Wouldn't It Be Nice: Reimagining US Taxation of Outbound Investment
Article, IBFD Thinker, Teacher, Traveler: Reimagining International Tax, 09.01.2021
The Morality – or Immorality – of International Tax Planning
Article, IBFD Thinker, Teacher, Traveler: Reimagining International Tax, 09.01.2021
IRS "Dirty Dozen" List Includes "Potentially" Abusive Use of U.S.-Malta Tax Treaty in Pension Plans
International Tax Alert, 08.17.2021
Congress Has The Power To Prevent A Repeat Of January 6
Article, Talking Points Memo, 08.16.2021
VIEWPOINT: The Future of Transfer Pricing
Article, Tax Notes International, 08.02.2021
Yellen's Global Minimum Tax Push Likely to Crash and Burn
Article, Roll Call Op-Ed, 07.23.2021
Reverse Claw-Backs Revisited: IRS Issues Post-Altera Guidance on Adjustments for Stock-Based Compensation Costs and Cost Sharing Arrangements
International Tax Alert, 07.22.2021
IRS to Taxpayers: Do You Trust Me?
Article, The Tax Advisor, 07.21.2021

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