In-depth guidance for handling virtually every issue and scenario involving federal income taxation. Written by the nation’s leading federal tax authorities, the U.S. Income Portfolios Library provides a single solution for researching, planning and implementing the most effective federal tax strategies.
Expert Analysis
Written by leading tax authorities, more than 200 Portfolios provide practical analysis for developing and implementing complex federal tax strategies and working through problems that arise. Portfolios are organized as follows:
- Compensation Planning
- Corporate Returns and Computation of Tax
- Income, Deductions, Credits and Computation of Tax
- Income Tax Accounting
- Natural Resources
- Other Pass-Through Entities
- Partnerships
- Procedure and Administration
- Real Estate
- U.S. Tax Overview
Practice Tools
- Checklists
- Federal Tax Calendar
- Interactive IRS Forms and State Forms (optional)
- Sample plans
- Tables, Charts, and Lists
- Other practice aids
Source Documents
- Final, Temporary, and Proposed Regulations
- IRS Documents — including Rev. Ruls., Rev. Procs., Notices and Announcements, PLRs and TAMs, CCAs, FSAs, and SCAs
- Treasury decision preambles
- IRS Publications
- Full Text of Federal Tax Cases from all federal courts from 1913 to date; Tax Court Rules; Court of Federal Claim Rules
- Selected full text of legislation with committee reports and BNA Tax Management summaries
- Circular 230
- Coordinated Issue Papers/Industry Specialization Papers — 2000-Present
News & Commentary
Daily Tax Report Highlights — Daily highlights from each issue of the Daily Tax Report, covering key legislative, regulatory, and legal tax developments.
Weekly Report — Timely notification of and concise reports on legislative, regulatory and judicial developments from the Treasury Department, Internal Revenue Service, the courts, and Congress.
Tax Management Memorandum — An authoritative outlook, including commentary from BNA’s Advisory Boards, on new issues, developments, trends, and strategies.
Insights & Commentary — Commentary by leading authorities on a variety of current and emerging tax issues.
Compensation Planning Journal (optional) — Monthly journal that keeps you abreast of such wide-ranging compensation planning issues such as qualified plan compliance, employment taxes, health care and other employee benefits, and non-qualified deferred compensation plans, including the impact of section 409A.
Financial Planning Journal (optional) — Monthly review of issues that affect how you advise your clients. It includes coverage of domestic and global economic trends, income tax planning, Social Security and Medicare, investment planning, retirement planning and insurance planning.
International Journal (optional) — Monthly resource on tax developments affecting international corporate and individual transactions includes a report on the status of all U.S. tax treaties and a cross-border view of tax issues between the U.S. and Canada.
Estates, Gifts and Trusts Journal (optional) — Bimonthly journal provides an ongoing perspective on today’s estate planning topics, such as marital deduction planning, estate and trust administration, charitable gifts, and valuation.
Real Estate Journal (optional) — Monthly journal offers the latest insights in the crucial areas of real estate tax planning, including passive loss rules, tax-free exchanges, workouts, REMICS and REITs. It includes analytical articles, practitioners’ comments, and analysis of recent developments.
Weekly State Tax Report (optional) — Weekly report provides state-by-state analysis of state code and regulations, state administrative and court decisions, and state administrative pronouncements. It covers income and franchise taxes, sales and use taxes, property taxes, miscellaneous taxes (including gross receipts taxes, excise taxes, and others) and other developments.
IRS Practice Adviser Report (optional) — Monthly report on IRS procedural developments, IRS positions, and new IRS trends and techniques. This report includes coverage of critical issues, court case updates, IRS rulings, changes to the IRM and other IRS pronouncements, plus insights and strategies from practitioners.
Accounting Policy & Practice Report (optional) — Biweekly report provides financial accounting policy-makers and their advisors with experts’ insights and guidance on emerging, evolving, and complex issues relating to accounting rules and principles, financial statements and disclosures, management control and analysis, auditing principles and standards, and accounting practice and responsibility.
Transfer Pricing Report (optional) — Practical service providing news and analysis on U.S. and other governments’ tax policies regarding intercompany transfer pricing and helps companies structure their operations to avoid double taxation.
Business Entities: C Corporations
The Attribution Rules (Portfolio 554)
Boot Distributions and Assumption of Liabilities (Portfolio 782)
Collapsible Corporations (Portfolio 793)
Corporate Acquisitions — A), B), and C)Reorganizations (Portfolio 771)
Corporate Acquisitions — D Reorganizations (Portfolio 772)
Corporate Bankruptcy (Portfolio 790)
Corporate Liquidations (Portfolio 784)
Corporate Overview (Portfolio 750)
Corporate Separations (Portfolio 776)
Dividends — Cash and Property (Portfolio 764)
Earnings and Profits (Portfolio 762)
Redemptions (Portfolio 767)
Single Entity Reorganizations: Recapitalizations and F Reorganizations (Portfolio 774)
Small Business Corporation Stock: Special Tax Incentives (Portfolio 760)
Stock Purchases Treated as Asset Acquisitions — Section 338 (Portfolio 788)
Stock Rights and Stock Dividends — Sections 305 and 306 (Portfolio 765)
Stock Sales Subject to Section 304 (Portfolio 768)
Structuring Corporate Acquisitions — Tax Aspects (Portfolio 770)
Transfers to Controlled Corporations: General (Portfolio 758)
Transfers to Controlled Corporations: Related Problems (Portfolio 759)
Business Entities: Corporate Returns and Computation of Tax
Accumulated Earnings Tax (Portfolio 796)
Charitable Contributions By Corporations (Portfolio 794)
Computation of Consolidated Tax Liability (Portfolio 756)
Consolidated Returns — Elections and Filing (Portfolio 754)
Consolidated Returns — Investment Subsidiaries (Portfolio 755)
Consolidated Returns — Limitations on Losses (Portfolio 757)
Corporate Alternative Minimum Tax (Portfolio 752)
Net Operating Losses and Other Tax Attributes — Sections 381, 382, 383, 384, and 269 (Portfolio 780)
Personal Holding Companies (Portfolio 797)
State Taxation of Mergers and Acquisitions (Portfolio 783)
Tax Shelters (Portfolio 798)
Business Entities: Partnerships
Audit Procedures for Pass-Through Entities (Portfolio 624)
Choice of Entity (Portfolio 700)
Family Limited Partnerships and Limited Liability Companies (Portfolio 722)
Partnership Transactions — Section 751 Property (Portfolio 720)
Partnerships — Allocation of Liabilities; Basis Rules (Portfolio 714)
Partnership Distributions; Death or Retirement of a Partner (Portfolio 716)
Partnerships — Disposition of Partnership Interests or Partnership Business; Partnership Termination (Portfolio 718)
Partnerships — Formation and Contributions of Property or Services (Portfolio 711)
Partnerships — Taxable Income; Allocation of Distributive Shares; Capital Accounts (Portfolio 712)
Partnerships—Conceptual Overview (Portfolio 710)
Business Entities: Other Pass-Through Entities
Disregarded Entities (Portfolio 704)
Hedge Funds (Portfolio 736)
Limited Liability Companies (Portfolio 725)
Private Equity Funds (Portfolio 735)
S Corporations: Formation and Termination (Portfolio 730)
S Corporations: Operations (Portfolio 731)
Taxation of Cooperatives and Their Patrons (Portfolio 744)
Taxation of Regulated Investment Companies (Portfolio 740)
Compensation Planning
Age, Sex and Disability Discrimination Employee Benefit Plans (Portfolio 363)
Cafeteria Plans (Portfolio 397)
Cash or Deferred Arrangements (Portfolio 358)
Church and Governmental Plans (Portfolio 372)
Compensating Employees with Insurance (Portfolio 386)
Deferred Compensation Arrangements (Portfolio 385)
Employee Benefits for Small and Mid-Sized Employers (Portfolio 353)
Employee Benefits for Tax-Exempt Organizations (Portfolio 373)
Employee Benefits for the Contingent Workforce (Portfolio 399)
Employee Fringe Benefits (Portfolio 394)
Employee Plans — Deductions, Contributions and Funding (Portfolio 371)
Employment Status — Employee v. Independent Contractor (Portfolio 391)
EPCRS — Plan Correction and Disqualification (Portfolio 375)
ERISA — Fiduciary Responsibility and Prohibited Transactions (Portfolio 365)
ERISA — Litigation, Procedure, Preemption and Other Title I Issues (Portfolio 374)
ESOPs (Portfolio 354)
Estate and Gift Tax Issues for Employee Benefit Plans (Portfolio 378)
Golden Parachutes (Portfolio 396)
International Pension Planning (Portfolio 320)
International Pension Planning — Puerto Rico (Portfolio 324)
IRAs (Portfolio 367)
Medical Plans — COBRA, HIPAA, HRAs, HSAs and Disability (Portfolio 389)
Multiemployer Plans — Special Rules (Portfolio 359)
Nondiscrimination Testing and Permitted Disparity Qualified Retirement Plans (Portfolio 356)
Nonstatutory Stock Options (Portfolio 383)
Pension Plan Terminations — Single Employer Plans (Portfolio 357)
Plan Qualification — Pension and Profit-Sharing Plans (Portfolio 351)
Plan Selection — Pension and Profit-Sharing Plans (Portfolio 350)
Qualified Plans — Investments (Portfolio 377)
Qualified Plans — IRS Determination Letter Procedures (Portfolio 360)
Qualified Plans — Taxation of Distributions (Portfolio 370)
Qualified Plans — Treatment Mergers, Acquisitions and Other Corporate Transactions (Portfolio 364)
Reasonable Compensation (Portfolio 390)
Reductions Force (Portfolio 398)
Reporting and Disclosure Under ERISA (Portfolio 361)
Restricted Property — Section 83 (Portfolio 384)
Securities Law Aspects of Employee Benefit Plans (Portfolio 362)
SEPs and SIMPLEs (Portfolio 368)
Specialized Qualified Plans — Cash Balance, Target, Age-Weighted and Hybrids (Portfolio 352)
State Taxation of Compensation and Benefits (Portfolio 366)
Statutory Stock Options (Portfolio 381)
Tax-Deferred Annuities — Section 403b) (Portfolio 388)
VEBAs and Other Self-Insured Arrangements (Portfolio 395)
Withholding, Social Security and Unemployment Taxes on Compensation (Portfolio 392)
Income, Deductions, Credits and Computation of Tax
Amortization of Intangibles (Portfolio 533)
Annuities, Life Insurance, and Long-Term Care Insurance Products (Portfolio 546)
At-Risk Rules (Portfolio 550)
C Corporations: The Attribution Rules (Portfolio 554)
Bad Debts (Portfolio 538)
Capital Assets (Portfolio 561)
Charitable Contributions: Income Tax Aspects (Portfolio 521)
Consolidated Returns — Limitations on Losses (Portfolio 757)
Deductibility of Illegal Payments, Fines, and Penalties (Portfolio 524)
Deductibility of Legal and Accounting Fees, Bribes and Illegal Payments (Portfolio 523)
Deduction Limitations: General (Portfolio 504)
Deductions: Overview and Conceptual Aspects (Portfolio 503)
Depreciation: General Concepts; Non-ACRS Rules (Portfolio 530)
Discharge of Indebtedness, Bankruptcy and Insolvency (Portfolio 540)
Divorce and Separation (Portfolio 515)
The Economic Substance Doctrine (Portfolio 508)
Entertainment, Meals, Gifts and Lodging — Deduction and Recordkeeping Requirements (Portfolio 520)
Equipment Lease Characterization (Portfolio 545)
Estimated Tax (Portfolio 581)
Farm and Ranch Expenses and Credits (Portfolio 607)
Federal Taxation of Software and E-Commerce (Portfolio 555)
Film Production: Basis Recovery and Federal Incentives (Portfolio 599)
Financial Instruments: Special Rules (Portfolio 186)
First-Year Expensing and Additional Depreciation
Gross Income: Overview and Conceptual Aspects (Portfolio 501)
Gross Income: Tax Benefit, Claim of Right and Assignment of Income (Portfolio 502)
Hobby Losses (Portfolio 548)
Home Office, Vacation Home, and Home Rental Deductions (Portfolio 547)
Income Tax Basis: Overview and Conceptual Aspects (Portfolio 560)
Income Tax Liability: Concepts and Calculation (Portfolio 507)
Interest Expense Deductions (Portfolio 536)
The Investment Credit and Cost Segregation (Portfolio 583)
Lobbying and Political Expenditures (Portfolio 613)
Loss Deductions (Portfolio 527)
The Mark-To-Market Rules of Section 475 (Portfolio 543)
Net Operating Losses — Concepts and Computations (Portfolio 539)
Net Operating Losses and Other Tax Attributes — Sections 381, 382, 383, 384, and 269 (Portfolio 780)
Noncorporate Alternative Minimum Tax (Portfolio 587)
Passive Loss Rules (Portfolio 549)
Real Estate Transactions by Tax-Exempt Entities (Portfolio 480)
Related Party Transactions (Portfolio 564)
Research and Development Expenditures (Portfolio 556)
Scholarships and Educational Expenses (Portfolio 517)
Section 199: Deduction Relating to Income Attributable to Domestic Production Activities (Portfolio 510)
Start-Up Expenditures (Portfolio 534)
State, Local, and Federal Taxes (Portfolio 525)
Tax Aspects of Franchising (Portfolio 559)
Tax Aspects of Restructuring Financially Troubled Businesses (Portfolio 541)
Tax Aspects of Settlements and Judgments (Portfolio 522)
Tax Credits: Concepts and Calculation (Portfolio 506)
Tax Incentives for Economically Distressed Areas (Portfolio 597)
Tax Planning for the Development and Licensing of Copyrights, Computer Software, Trademarks and Franchises (Portfolio 558)
Tax Planning for the Development and Licensing of Patents and Know-How (Portfolio 557)
Taxation of Equity Derivatives (Portfolio 188)
Time Value of Money: OID and Imputed Interest (Portfolio 535)
Trade Associations (Portfolio 614)
Trade or Business Expenses and For-Profit Activity Deductions (Portfolio 505)
Transactions Stock, Securities and Other Financial Instruments (Portfolio 184)
Travel and Transportation Expenses — Deduction and Recordkeeping Requirements (Portfolio 519)
Income Tax Accounting
Accounting for Long-Term Contracts (Portfolio 575)
Accounting Methods — Adoption and Changes (Portfolio 572)
Accounting Methods — General Principles (Portfolio 570)
Accounting Periods (Portfolio 574)
Inventories: General Principles; LIFO Method (Portfolio 578)
Reporting Farm Income (Portfolio 608)
Section 482 Allocations: General Principles the Code and Regulations (Portfolio 551)
Section 482 Allocations: Judicial Decisions and IRS Practice (Portfolio 553)
Section 482 Allocations: Specific Allocation Methods and Rules the Code and Regulations (Portfolio 552)
Uniform Capitalization Rules: Inventory; Self-Constructed Assets; Real Estate (Portfolio 576)
Uniform Capitalization Rules: Special Topics; Method Change Rules (Portfolio 577)
Natural Resources
Mineral Properties — Exploration, Acquisition, Development and Disposition (Portfolio 601)
Mineral Properties Other Than Gas and Oil — Operation (Portfolio 603)
Oil and Gas Transactions (Portfolio 605)
Timber Transactions (Portfolio 610)
Procedure and Administration
Audit Procedures for Pass-Through Entities (Portfolio 624)
Civil Tax Penalties (Portfolio 634)
Compelled Production of Documents and Testimony Tax Examinations (Portfolio 633)
Discharge of Indebtedness, Bankruptcy and Insolvency (Portfolio 540)
Federal Tax Collection Procedure — Defensive Measures (Portfolio 638)
Federal Tax Collection Procedure — Liens, Levies, Suits and Third Party Liability (Portfolio 637)
Innocent Spouse Relief (Portfolio 645)
IRS National Office Procedures — Rulings, Closing Agreements (Portfolio 621)
IRS Procedures: Examinations and Appeals (Portfolio 623)
Limitations Periods, Interest on Underpayments and Overpayments, and Mitigation (Portfolio 627)
Obtaining Information from the Government — Disclosure Statutes (Portfolio 625)
Practice Before the IRS; Attorney's Fees Tax Proceedings (Portfolio 620)
Refund Litigation (Portfolio 631)
Responsible Person and Lender Liability for Trust Fund Taxes — Sections 6672 and 3505 (Portfolio 639)
Tax Court Litigation (Portfolio 630)
Tax Crimes (Portfolio 636)
Transferee Liability (Portfolio 628)
U.S. Federal Tax Research (Portfolio 100)
Real Estate
Capital Assets (Portfolio 561)
Cooperative and Condominium Apartments (Portfolio 596)
Depreciation Recapture — Sections 1245 and 1250 (Portfolio 563)
Depreciation: MACRS and ACRS (Portfolio 531)
Home Office, Vacation Home, and Home Rental Deductions (Portfolio 547)
Installment Sales (Portfolio 565)
Interest Expense Deductions (Portfolio 536)
Involuntary Conversions (Portfolio 568)
Passive Loss Rules (Portfolio 549)
Real Estate Investment Trusts (Portfolio 742)
Real Estate Leases (Portfolio 593)
Real Estate Mortgages (Portfolio 592)
Rehabilitation Tax Credit and Low-Income Housing Tax Credit (Portfolio 584)
REMICs, FASITs and Other Mortgage-Backed Securities (Portfolio 741)
Structuring Real Estate Joint Ventures with Private REITs (Portfolio 743)
Tax Implications of Home Ownership (Portfolio 594)
Taxation of Real Estate Transactions — An Overview (Portfolio 590)
Taxfree Exchanges Under Section 1031 (Portfolio 567)
Note: This product is a component of the BNA Tax and Accounting Center. Your 15-day Web trial to the Center includes full access, allowing you to explore all areas of tax and accounting analysis, primary sources, practice tools and more. You can find more information on the Library here.
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A
Howard Abrams, Esq.Howard E. Abrams, Esq., B.A., University of California at Irvine (1976; summa cum laude); J.D., Harvard Law School (1980; cum laude); Law Clerk to the Honorable Theodore Tannenwald, Jr., Chief Judge, United States Tax Court (1980-82); Professor, Emory Law School, since 1983; Adjunct Professor, University of Georgia College of Law, since 1993; Visiting Professor, Cornell Law School (1987-88); Director of Real Estate Tax Knowledge, Deloitte & Touche (1989-90); Of Counsel, Steptoe & Johnson (2003-04); co-author, Federal Income Taxation of Corporations and Shareholders (Aspen Law & Business: 3d ed. 2000); co-author, Federal Corporate Taxation (Foundation Press: 5th ed. 2002); co-author, Fundamentals of US Taxation (Kluwer Law International: 1999); member, District of Columbia Bar; member, American Law Institute; member, American Bar Association, Tax Section.
Disregarded Entities (Portfolio 704) Donald C. AlexanderDonald C. Alexander (deceased), B.A., Yale University (with honors, 1942); LL.B., Harvard University (magna cum laude, 1948). Awarded LL.D., St. Thomas Institute (1975) and Capital University (1989). Served as Commissioner of Internal Revenue (1973-1977); member of the Commission on Federal Paperwork (1975-1977), the Interior Department's Coal Leasing Commission (1983-1984), the Martin Luther King, Jr. Federal Holiday Commission (1992-1997); Chairman of the Internal Revenue Service Exempt Organizations Advisory Group (1987-1989); Harvard Law School Visiting Committee (2000-Present); Harvard Board of Overseers’ Committee on University Resources (2002-Present). Member of the American Bar Association, serving as the Vice Chairman of the Tax Section (1968-1969), the American Law Institute, and a fellow of the American College of Tax Counsel and the American College of Employee Benefits Counsel. Member of the District of Columbia, New York and Ohio Bars.
IRS Procedures: Examinations and Appeals (Portfolio 623) Peter J. Allman, Esq.Peter J. Allman, B.A., University of Maryland (1976); J.D., The Washington College of Law, The American University (1980); L.L.M., M.S.A., Georgetown University (1981, 1982); member of the District of Columbia, Connecticut, Massachusetts and New York Bars.
Withholding, Social Security and Unemployment Taxes on Compensation (Portfolio 392) Reuven S. Avi-YonahReuven S. Avi-Yonah (B.A., Hebrew University, 1983; Ph.D., Harvard University, 1986; J.D., Harvard Law School, 1989) is Assistant Professor of Law, Harvard Law School, where he teaches domestic and international taxation. Mr. Avi–Yonah is a member of the New York and Massachusetts bars and co–chairs the tax policy committee of the New York State Bar Association Tax Section. He participated in preparing the Tax Section's reports on proposed legislation on amortization of intangibles and has published several articles and comments on the leading Supreme Court case in this area, Newark Morning Ledger Co. v. United States, 113 S. Ct. 1670 (1993).
The Attribution Rules (Portfolio 554)Collapsible Corporations (Portfolio 793)Transfer Pricing: Judicial Strategy and Outcomes (Portfolio 888)
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Noah S. Baer, Esq.Noah S. Baer, B.A., Yeshiva University; J.D., Columbia University; M.L.T., Georgetown University; Executive Director, Ernst & Young, National Tax Department; Domestic and International Tax Counsel, Mobil Corporation; Senior Attorney, Office of Chief Counsel (Passthroughs and Special Industries Division), Internal Revenue Service; Senior Litigation Attorney, Office of Chief Counsel, Department of Energy; Litigation Associate, Tenzer, Greenblatt, Fallon & Kaplan, New York, NY; Member, Maryland and District of Columbia bars; Speaker at various natural resource tax conferences.
Oil and Gas Transactions (Portfolio 605) Lewis T. Barr, Esq.Lewis T. Barr, B.S., Economics, Wharton School of Finance, University of Pennsylvania (1964); J.D., University of Michigan Law School (1967); member of Ohio Bar; American College of Tax Counsel; American Law Institute; American College of Probate Counsel; contributor to various tax publications and lecturer at various tax institutes.
Net Operating Losses and Other Tax Attributes — Sections 381, 382, 383, 384, and 269 (Portfolio 780) Beth M. Benko, CPA Esq.Beth M. Benko, B.S.B.A., cum laude, Bowling Green State University (1990); J.D., Marshall-Wythe School of Law of the College of William and Mary in Virginia (1998); member, the Virginia State Bar and the District of Columbia Bar; member, the American Bar Association — Chair, Section of Taxation Tax Accounting Committee Subcommittee on Current Developments; adjunct professor, Georgetown University School of Law; certified public accountant, State of Ohio.Section 199: Deduction Relating to Income Attributable to Domestic Production Activities (Portfolio 510) Bradley T. Borden, Esq.Bradley T. Borden, B.B.A., M.B.A., Idaho State University; J.D. (Order of the Coif), LL.M. (Taxation), University of Florida Levin College of Law; Associate Professor of Law, Washburn University School of Law (courses include Taxation of Individual Income; Taxation of Partnerships and Partners; Taxation of Property Transactions; Taxation of Corporations and Shareholders; Tax Policy Seminar); Of Counsel, Oppenheimer, Blend, Harrison & Tate, Inc., San Antonio, Texas; admitted to practice, Texas, U.S. Tax Court; Certified Public Accountant; member, American Bar Association Section of Taxation (John S. Nolan Tax Law Fellow; Vice Chair, Sales, Exchanges & Basis Committee); member, Executive Committee, Kansas Bar Association Tax Law Section; author, books on §1031 (Tax-Free Like-Kind Exchanges (Civic Research Institute, 2008); Tax-Free Swaps: Using Section 1031 Like-Kind Exchanges to Preserve Investment Net Worth (DNA Press, 2007)); author, various articles in leading tax journals (including Journal of Taxation; Real Estate Taxation; Tax Management Memorandum; Tax Management Real Estate Journal; Tax Notes; Taxes: The Tax Magazine) and several law reviews (including Florida Law Review; Houston Law Review; Kansas Law Review; South Carolina Law Review; Virginia Tax Review); frequent speaker, tax law topics.
Real Estate Transactions by Tax-Exempt Entities (Portfolio 480)Real Estate Transactions by Tax-Exempt Entities (Portfolio 591) Janine H. Bosley, Esq.Janine H. Bosley, University of Miami (B.S.B.A. 1981, M.P.A. 1982, J.D. 1986); formerly, Senior Attorney, Office of Associate Chief Counsel (Employee Benefits and Exempt Organizations), Internal Revenue Service; Member of the Virginia, United States Tax Court, and United States Supreme Court Bars; Liaison Member of the IRS Employee Benefits Conference Committee, Southeast Region; Vice Chair of the American Bar Association, Tort and Insurance Practice Section, Committee on Employee Benefits; and Member of the American Bar Association Section of Taxation, Committee on Employee Benefits.
Employee Benefits for Small and Mid-Sized Employers (Portfolio 353)Qualified Plans — Taxation of Distributions (Portfolio 370) Lawrence Brody, Esq.
Lawrence Brody, partner, Bryan Cave LLP; B.S., University of Pennsylvania (Wharton) (1964); J.D., Washington University School of Law (1967); LL.M. in Taxation, New York University School of Law (1968); Partner, Bryan Cave LLP, an international law firm, resident in the St. Louis office, and member of its Private Client Service Group and its Technology, Entrepreneurial & Commercial Practice Client Service Group; adjunct professor, Washington University School of Law, teaching Estate Planning and Drafting; visiting adjunct professor, the University of Miami Law School, teaching a course on Life Insurance; author or co-author, numerous articles and books on the use of life insurance in estate and employee benefit planning, including two BNA Tax Management Portfolios, two books for the National Underwriter Company, and a number of volumes in the ABA Insurance Counselor Series; fellow, American College of Trust and Estate Counsel (ACTEC) and American College of Tax Counsel; frequent participant, ALI-ABA programs and Society of Financial Professionals programs and teleconferences; speaker, all major life insurance industry programs (including the MDRT, the Top of the Table, AALU and the International Forum), many local estate planning council meetings, a number of state bar association conferences, and many national estate planning programs; member, Advisory Committee for the Philip E. Heckerling Institute on Estate Planning of the University of Miami School of Law; member, Editorial Boards of BNA Tax Management's Estates, Gifts, and Trusts Journal, and the Society of Financial Service Professionals CLU Journal; designated, Accredited Estate Planner by the National Association of Estate Planners and Councils, and one of 10 individuals awarded its Distinguished Accredited Estate Planner designation in the initial class, in 2004.
Compensating Employees with Insurance (Portfolio 386)Section 2035 Transfers (Portfolio 818)Compensating Employees with Insurance (Portfolio 828) Gregory K. Brown, Esq.Gregory K. Brown, University of Kentucky (B.S. 1973), University of Illinois (J.D. 1975); member, Illinois Bar. Past Chairman, member, Legislative and Regulatory Advisory Committee, The ESOP Association. Past Member, Board of Directors, The ESOP Association. Past Chairman, Chicago Bar Association, Employee Benefits Committee. Member, ABA Tax Section, Employee Benefits Committee.
ESOPs (Portfolio 354) Karen B. BrownKaren B. Brown, B.A., Princeton University; J.D., LL.M., New York University, the Donald Phillip Rothschild Research Professor of Law at the George Washington University School of Law, where she teaches courses in Federal Income Taxation, Corporate Taxation, and International Taxation. Before joining the faculty at George Washington University, Professor Brown was Professor of Law and Associate Dean for Academic Affairs at the University of Minnesota Law School and Professor of Law at Brooklyn Law School. She has published numerous articles concerning corporate and international taxation. Professor Brown is co-author of an international tax transactions treatise and co-editor of a book on taxation reform. She is a member of the International Fiscal Association.
The Attribution Rules (Portfolio 554)Innocent Spouse Relief (Portfolio 645)
C
Oguz Caginalp, Esq.Oggie Caginalp, B.A., Tufts University; M.B.A. New York University Graduate School of Business; J.D., Boston College Law School; LL.M (in Taxation), New York University School of Law; Attorney, Tax Department, Brown & Wood; Attorney, Tax Department, Rogers & Wells; Vice President and Senior Tax Counsel, Corporate Tax Division, Citibank, N.A; Vice President, Capital Structuring Group, Citibank, N.A, Senior Vice President and Head of Tax, Commerzbank Capital Markets Corporation (2000-present).
The Mark-To-Market Rules of Section 475 (Portfolio 543) Michael Carnevale, CPA Esq.Michael K. Carnevale, Esq., University of Michigan (1982); University of Detroit (1990). Certified Public Accountant (New York, New Jersey, Michigan); Partner, Deloitte Tax LLP; member, American Institute of Certified Public Accountants, Michigan Society of Certified Public Accountants, American Bar Association, Michigan Bar Association, and National Association of Real Estate Investment Trusts.
Real Estate Investment Trusts (Portfolio 742) James E. Carreon, Esq.James E. Carreon, J.D., Southwestern University School of Law; B.S. and B.A., University of Southern California; State Bar of California; Adjunct Professor, Golden Gate University, Master of Tax Program.
Related Party Transactions (Portfolio 564) Elizabeth A. Case, Esq.Elizabeth A. Case, B.A., Millsaps College; M.B.A., Southern Methodist University; formerly Special Assistant to the Deputy Chief Counsel, Internal Revenue Service; Participant, AICPA Partnership Taxation Technical Resource Panel.
Limited Liability Companies (Portfolio 725) R. Lee Christie, Esq.Lee Christie is a partner in the Chicago office of Hopkins & Sutter whose practice focuses on tax matters for insurance industry clients, including property and casualty insurers, life and health insurers, HMOs, Blue Cross organizations, insurance trade associations, and insurance guaranty associations. He graduated from Illinois Wesleyan University in 1981 and Harvard Law School in 1984. Lee has served as Chair of the Subcommittee on Life Insurance Companies of the ABA Tax Section Committee on Insurance Companies.
Annuities, Life Insurance, and Long-Term Care Insurance Products (Portfolio 546) James T. Chudy, Esq.James T. Chudy, B.S. with Honors, Phi Beta Kappa, University of Wisconsin–Madison (1981); J.D., Harvard Law School (1984); Executive Editor, Harvard Civil Rights-Civil Liberties Law Review; The Association of the Bar of the City of New York (Council on Taxation, Secretary, 1990–1993).
Stock Purchases Treated as Asset Acquisitions — Section 338 (Portfolio 788) Bruce A. Cohen, Esq.Bruce A. Cohen, B.A., Case Western Reserve University (1984) (Phi Beta Kappa, summa cum laude); J.D., Columbia University (1987); Associate International Tax Counsel and Attorney Advisor, Office of Internal Tax Counsel, Department of the Treasury, 1995-1997; Partner, Baker & McKenzie LLP, 2001-2007; Harlan Fiske Stone Scholar; member, Internal Fiscal Association; member, State Bar of California, District of Columbia Bar, Illinois State Bar Association, Tax Court Bar, American Bar Association Section on Taxation.
Federal Taxation of Software and E-Commerce (Portfolio 555)Research and Development Expenditures (Portfolio 556) Toby Cozart, Esq.Toby Cozart, B.A., University of North Carolina (1974); J.D., Duke University (1978); M.S. in Philosophy, University of North Carolina (1979); LL.M. in Taxation, New York University School of Law (1981). Law office, Piedmont, California. Previously: Tax Counsel, GATX Capital Corporation, San Francisco, California; Partner, Lillick, McHose & Charles, San Francisco, California; Associate, Morgan, Lewis & Bockius, New York, New York; Staff Counsel, Subcommittee on Oversight, Committee on Ways and Means, U.S. House of Representatives, Washington, D.C.; Member of the Bars of the District of Columbia, New York, California, and the United States Tax Court.
Equipment Lease Characterization (Portfolio 545)Equipment Leasing: Substance and Form (Portfolio 544) Robert J. Crnkovich, Esq.Robert J. Crnkovich, B.S., J.D., Marquette University; LL.M. in Taxation, Georgetown University Law Center; Adjunct Professor, Georgetown University Law Center; member, State Bars of Wisconsin, California, and District of Columbia.
Limited Liability Companies (Portfolio 725) Frank Cummings, Esq.Frank Cummings, B.A. with high honors, Hobart College (1951), Phi Beta Kappa; M.A., Columbia University (1955); L.L.B., Columbia University School of Law (1958), Harlan Fiske Stone Scholar; Articles Editor, Columbia Law Review; Chairman, ALI-ABA Annual Course in Employee Benefits Litigation; Co-Chairman, ALI-ABA Annual Course in Employment & Labor Relations Law for the Corporate Counsel & General Practitioner; member, The American Law Institute, American Bar Association; former Chairman, District of Columbia Bar Association (Labor Committee); Association of the Bar of the City of New York, District of Columbia Bar and the State Bar of New York; Lecturer in Law, University of Virginia Law School; former member, U.S. Department of Labor Advisory Council on Employee Welfare and Pension Benefit Plans.
Pension Plan Terminations — Single Employer Plans (Portfolio 357)
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James P. DeBree, Jr. CPAJames P. de Bree, Jr., B.S., California State University Northridge (1975). Certified Public Accountant (California); Partner, Deloitte Tax LLP; member, American Institute of Certified Public Accountants, California Society of Certified Public Accountants, National Association of Real Estate Investment Trusts; author of numerous articles on REITs and REIT taxation; frequent speaker on REIT-related matters.
Real Estate Investment Trusts (Portfolio 742) Louis H. Diamond, Esq.Louis H. Diamond, Esq.; LL.M. in Taxation, Georgetown University Law Center; J.D., Cum Laude, George Washington University National Law Center; B.A., George Washington University; Managing Member of Diamond ESOP Advisors PLLC, is one of the leading ESOP (Employee Stock Ownership Plan) attorneys in the country. Mr. Diamond is a past chairman of the ESOP Association’s Legislative and Regulatory Advisory Committee. He previously served as attorney advisor at the United States Tax Court, is a Charter Fellow of the American College of Employee Benefits Counsel and a Fellow of the American College of Tax Counsel. His work with ESOPs is all encompassing, ranging from representing owners selling stock to an ESOP, employees pooling ESOP funds to purchase their division/subsidiary from corporations large and small, banks and others making ESOP loans and ESOPs themselves and their trustees. Representing the employees of the Illinois Institute of Technology Research Institute (now Alion Science and Technology) in a $130 million employee buyout of its operating assets is among Mr. Diamond’s most notable ESOP achievements.
Accounting Methods — General Principles (Portfolio 570) Beth J. Dickstein, Esq.Beth J. Dickstein, B.S., University of Illinois (1985, with highest honors); J.D., University of Pennsylvania Law School (1988, cum laude); Certified Public Accountant; member of the Tax Section of the American Bar Association.
Qualified Plans — Investments (Portfolio 377) Glenn W. Dowd, Esq.Glenn W. Dowd, Central Connecticut State University (B.A. cum laude, 1984), University of Connecticut School of Law (J.D. high honors, 1989); member, Connecticut Bar; associate, Day, Berry & Howard.
Reductions Force (Portfolio 398) David S. Dunkle, Esq.David S. Dunkle, B.A., Virginia Military Institute (Honors in English 1966); J.D., University of North Carolina Law School (member of Law Review 1969); LL.M. (Taxation) Georgetown Law Center (1970); member Alabama State Bar, North Carolina State Bar, American Bar Association (Section of Taxation); contributor to The Journal of Taxation, TAXES, Law Office Economics and Management, The North Carolina Bar Association BAR NOTES, and The North Carolina Law Review; author of treatise: Guide to Pension and Profit Sharing Plans, Shepard's/McGraw–Hill, 1984.
VEBAs and Other Self-Insured Arrangements (Portfolio 395)
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Bruce N. Edwards, Esq.Bruce N. Edwards, B.A., The Colorado College; J.D., University of Washington School of Law; LL.M. (in Taxation), New York University; former Law Clerk to the Honorable Shiro Kashiwa, Associate Judge, the United States Court of Claims (now the Court of Appeals for the Federal Circuit); former New Decisions Editor, The Journal of Taxation; selected as Super Lawyer, Washington Law & Politics (2005, 2004, 2003); author, “Understanding and Making the New Section 646 Election for Alaska Native Settlement Trusts,” 18 Alaska Law Review 219 (Duke University 2001); “Understanding and Using ‘Partnership Redemptions' in the Context of Section 1(h),” 45 Tax Mgmt. Memo. No. 19, 1 (Sept. 20, 2004); 568-3rd T.M., Involuntary Conversions; 594-2nd T.M., Tax Implications of Home Ownership; Tax Practice Series: Chapter 1510, Tax Free Exchanges; Chapter 1520, Involuntary Conversions; Chapter 2650, Taxation of Timber; Chapter 3880, Tax Court Litigation; Chapter 3890, Refund Litigation; Chapter 3850, IRS Audit Procedures; Chapter 3860, Statute of Limitations; member, Washington and Alaska Bars; member, American Bar Association (Section of Taxation, Committee on Court Procedure); member, American College of Tax Counsel.
Involuntary Conversions (Portfolio 568)Tax Implications of Home Ownership (Portfolio 594)Timber Transactions (Portfolio 610) William E. Elwood, Esq.William E. Elwood, B.S., Pennsylvania State University (1965); J.D., University of Pennsylvania Law School (1968); LL.M. (Taxation), Georgetown University (1975); also attended Universität zu Köln Cologne, Germany (1963) and the Hague Academy of International Law (1967); formerly Technical Attorney, Tax Court Litigation Division, Office of Chief Counsel, Internal Revenue Service (1970-1974); and associated with Lee, Toomey & Kent, attorneys, Washington, D.C. (1974-1977); Tax Counsel and subsequently Assistant General Counsel, Communications Satellite Corporation, Washington, D.C. (1977-1985); Vice President and Tax Counsel, Primark Corporation, McLean, Virginia (1985-1987); Served as National Federal Tax Chairman, Tax Executives Institute (1984-1985); Corporation Department Editor, The Tax Times (1984-1987); Articles Editor, The Tax Lawyer (1976-1980); member of the District of Columbia, Michigan and Pennsylvania Bars; American Bar Association, Section of Taxation, and Metropolitan Detroit Bar Association.
Employee Fringe Benefits (Portfolio 394)
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Charles E. Falk, Esq.Charles Edward Falk, B.A. (in economics), University of Kansas (1970); M.S. (in accounting), The University of Virginia (1976); J.D., Washington and Lee School of Law (1979); LL.M. (in taxation), New York University School of Law (1981); LL.M. in Corporation Law (Bankruptcy and Securities Laws), New York University School of Law (1991); Principal, Mortenson and Associates, Cranford, N.J.; member, New Jersey and Virginia Bars; Certified Public Accountant, New Jersey and Virginia; author, Tax Management Portfolio, Tax Planning for the Development and Licensing of Patents and Know–How, No. 557.
Tax Planning for the Development and Licensing of Patents and Know-How (Portfolio 557)Tax Planning for the Development and Licensing of Copyrights, Computer Software, Trademarks and Franchises (Portfolio 558) Felicia A. Finston, Esq.Felicia A. Finston, Arizona State University (B.S. in Personnel Management, magna cum laude, 1982); University of Utah (M.S. in Human Resource Management, with honors, 1983); University of New Mexico School of Law (J.D., with honors, 1986); member, State Bar of Texas, Dallas Bar Association, State Bar of Arizona, Maricopa County Bar Association, American Bar Association, and SouthWest Benefits Association.
Plan Qualification — Pension and Profit-Sharing Plans (Portfolio 351) James W. Forsyth, Esq.James W. Forsyth, B.S. (summa cum laude), West Liberty State College (1983); J.D. (Order of the Coif), West Virginia University College of Law (1986); LL.M. (Taxation), University of Florida College of Law (1989); admitted to practice in Pennsylvania and West Virginia; member, American Bar Association, Section of Taxation, Committee on Partnerships; member, Allegheny County and Pennsylvania Bar Associations; member, West Virginia Bar Association; certified public accountant (1988); member, American Institute of Certified Public Accountants; member, West Virginia Society of Certified Public Accountants; adjunct lecturer, West Virginia University College of Law (1993-2001).
Stock Rights and Stock Dividends — Sections 305 and 306 (Portfolio 765) Anjanette T. Frias, Esq.Anjanette T. Frias, B.A. (cum laude), Creighton University (1993); J.D., Emory University School of Law (1996); member, Tennessee Bar Association (1996-2002); co-author, “Consolidated Return Election Offers Tax Advantages—With Complexity,” Tax Strategies (Sept. 2001); Ernst & Young, LLP (1996-2001); Responder, Mergers & Acquisitions Segment, Ernst & Young's Online Tax Advisor (2001-2003).
Corporate Overview (Portfolio 750)Dividends — Cash and Property (Portfolio 764) Richard C. Fung, Esq.Richard C. Fung, Amherst College (B.A., cum laude, 1991); Columbia University School of Law (J.D. 1994); Associate, Skadden, Arps, Slate, Meagher & Flom LLP (1994-2001); Senior Manager, Ernst & Young LLP, National Office West, Mergers & Acquisitions; contributing author, Practising Law Institute: Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings (2001).
Personal Holding Companies (Portfolio 797)
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William Galanis, Esq.William Galanis, LL.M., in Taxation, (with distinction), from Georgetown University; J.D. from the Columbia School of Law, Catholic University; B.S. in Accounting, (cum laude) from Mt. St. Mary's College. Member of the District of Columbia and Maryland State bar associations. Formerly Attorney/Advisor, Office of Chief Counsel, Internal Revenue Service.
Earnings and Profits (Portfolio 762) John A. Galotto, Esq.John A. Galotto, B.A., Johns Hopkins University (1988); J.D., Columbia Law School (1993); Senior Editor, Columbia Law Review; Trial Attorney, U.S. Department of Justice, Tax Division, Civil Trial and Criminal Enforcement Sections, 1995-2000; Special Assistant U.S. Attorney, District of Columbia, 1999; Law Clerk to U.S. District Court Judge Edward Rafeedie, Central District of California, 1993-1994; co-author: “Right To Counsel: Courts Adhere to Bright-Line Limits,” ABA Criminal Justice Magazine, Summer, 2001 at 4; co-author, “Sensible Decision on Admissibility of Witness Guilty Pleas Repudiated in Third Circuit, but Dissenters Offer Hope in Other Circuits,” White Collar Crime Reporter, June/July 2000, at 1; co-author, “The COSO Report on Internal Control: Implications for Public Companies and Executives,” Insights, August 1993, at 29; member, American Bar Association, Section of Taxation, Committee on Court Procedure; member, bars of the District of Columbia, New York and Illinois.
Obtaining Information from the Government — Disclosure Statutes (Portfolio 625) Nancy J. Glover, CPA Esq.Nancy J. Glover, B.S., magna cum laude, University of Utah (1985); M.S.T., DePaul University (1992); J.D., Chicago-Kent College of Law (1998); member, American Institute of Certified Public Accountants and the Illinois Institute of Certified Public Accountants; frequent guest speaker, Tax Executives Institute, Inc. (TEI), FSC/DISC Tax Association, Inc. (FDTA), and Council for International Tax Education (CITE).
Section 199: Deduction Relating to Income Attributable to Domestic Production Activities (Portfolio 510) Carlos Gonzalez-Padro, Esq.Carlos Gonzalez-Padro, B.B.A. with a major in accounting, University of Puerto Rico (1991); J.D., University of Puerto Rico (1994); LLM in Taxation with an Employee Benefits Certificate, Georgetown University Law Center (2001). Certified Public Accountant; Member, Georgia, Puerto Rico, and Washington, DC Bar Associations; Member of the American Bar Association Section of Taxation; advisor to the U.S. Treasury Department and the IRS on Puerto Rico plan initiatives; frequent lecturer and author of various articles on employee benefits in Puerto Rico.
International Pension Planning — Puerto Rico (Portfolio 324) Luis Granados, Esq.Luis Granados, Brown University (A.B. 1975), Georgetown University Law Center (J.D. 1978); member, District of Columbia and Maryland Bars. Past Chairman, Legislative and Regulatory Advisory Committee, The ESOP Association.
ESOPs (Portfolio 354)
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Russell E. HallRussell E. Hall, J.D., Fordham Law School (1978), LL.M. in taxation, New York University School of Law (1979), B.A., S.U.N.Y. at Albany (1975); member, New York State Bar; member, Retirement Security Committee, ERISA Industry Committee; member, Tax Law Section, American Bar Association; member, International Pension and Employee Benefit Lawyers Association (IPEBLA).
International Pension Planning (Portfolio 320) R. Arnold Handler, Esq.R. Arnold Handler, B.A., University of Rochester (undergraduate study also at London School of Economics); J.D., Harvard Law School; LL.M (in Taxation), New York University School of Law; Captain, Judge Advocate Generals Corps, U.S. Army; Attorney, Tax Department, Carter, Ledyard & Milburn; Senior Tax Attorney, Mobil Corporation; Senior International Tax Counsel, Citigroup (1990-present).
The Mark-To-Market Rules of Section 475 (Portfolio 543) Richard M. Hervey, Esq.Richard M. Hervey, Dechert LLP, New York, NY; B.A., Herbert Lehman College (1972); M.A., University of California, Berkeley (1975); J.D., Harvard Law School (1978); admitted, New York Bar; member, American Bar Association (Section of Taxation); Committee on Regulated Investment Companies, New York State Bar Association (Section on Taxation).
Taxation of Regulated Investment Companies (Portfolio 740) Barry Herzog, Esq.Barry Herzog, B.A., Yeshiva University (1987); J.D., Columbia University (1991); member, New York State Bar Association, Committee on Corporations; member, American Bar Association, Section of Taxation; member, New York State Bar; co-author, Tax Management Portfolio No. 561, Capital Assets.
Capital Assets (Portfolio 561)Transfers to Controlled Corporations: General (Portfolio 758)Transfers to Controlled Corporations: Related Problems (Portfolio 759) David A. Hildebrandt, Esq.David A. Hildebrandt, B.S., Brigham Young University (1967); J.D., Order of the Coif, University of Wisconsin (1970); note and comment editor, Wisconsin Law Review (1970); member, American Bar Association Section of Taxation, District of Columbia Bar, State Bar of Wisconsin, U.S. Supreme Court; Certified Public Accountant, Wisconsin (1974).
Qualified Plans — IRS Determination Letter Procedures (Portfolio 360)Qualified Plans — Treatment Mergers, Acquisitions and Other Corporate Transactions (Portfolio 364) Bruce I. Hochman, Esq.Bruce I. Hochman, B.A., University of Toronto and University of California at Los Angeles (1949); J.D., University of California at Los Angeles (1952); Graduate Certificate in Taxation, University of Southern California (1957). Assistant U.S. Attorney, Southern District of California, Tax Division (1953–1956). Hearing Officer, Department of Justice (195801968). Member: American Bar Association, State Bar of California. Fellow, American College of Trial Lawyers. Certified specialist, Criminal and Taxation Law, California Board of Legal Specialization. Principal – Hochman, Salkin and DeRoy, P.C., Beverly Hills, California, a firm specializing in federal and state taxation, corporation law and civil, criminal and tax litigation.
Tax Crimes (Portfolio 636) Philip J. Holthouse, Esq.Philip J. Holthouse, B.S., University of Southern California (summa cum laude, 1981); M.B.T., University of Southern California (1986); J.D., Loyola Law School — Los Angeles (Order of the Coif, 1993); adjunct professor, University of Southern California Master of Business Taxation Program (1988 – ); author of numerous articles on federal taxation; member of the American Bar Association, State Bar of California, American Institute of Certified Public Accountants, California Society of CPAs; Partner — Holthouse Carlin & Van Trigt LLP (CPAs); Partner — Sherry, Coleman & Holthouse LLP (Attorneys at Law).
Real Estate Leases (Portfolio 593) Edward B. Horahan IIIEd Horahan currently acts as of counsel to the Groom Law Group, Chartered, in Washington, D.C. A 1976 graduate of Yale Law School, he formerly served on the staff of the Securities and Exchange Commission and litigated ERISA cases while with the Solicitor's Office of the Department of Labor. In the private sector, he was a partner in the Washington offices of New York City law firms and the proprietor of his own law practice.
ERISA — Fiduciary Responsibility and Prohibited Transactions (Portfolio 365) Helen M. Hubbard, Esq.Helen M. Hubbard, Esq., B.B.A., Texas Tech University (1975); J.D., Southern Methodist University School of Law (1987, magna cum laude); Law Clerk to the Honorable Irving L. Goldberg, U.S. Court of Appeals for the Fifth Circuit (1987-88); Tax Legislative Counsel, United States Department of the Treasury (2002-05); Partner, Baker & McKenzie LLP; member, State Bar of Texas, District of Columbia Bar, American Bar Association Section of Taxation (Council, 2006-present; Chair, Simplification Committee, 2007-present; Assistant Secretary, 2004-05; Chair, Tax Accounting Committee, 1996-98); Adjunct Professor of Law at Southern Methodist University Dedman School of Law (2006) and Georgetown University Law Center (1996-2001); Fellow, American College of Tax Counsel; Certified Public Accountant.
Federal Taxation of Software and E-Commerce (Portfolio 555)
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Kathy Davidson Ireland, Esq.Kathy Davidson Ireland, B.S., Lebanon Valley College (1977); J.D., Order of the Coif, Marshall-Wythe School of Law, College of William & Mary; Executive Editor for Student Contributions, William & Mary Law Review (1980), LL.M., Labor Law, The National Law Center, George Washington University (1982); member: District of Columbia Bar, Maryland Bar.
Qualified Plans — IRS Determination Letter Procedures (Portfolio 360)
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Carl M. Jenks, Esq.Carl M. Jenks, J. D. Harvard Law School (1980); Ph.D. Duke University (1979), M.A. Duke University (1973); B.A. Carleton College (1967).
Corporate Bankruptcy (Portfolio 790)
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Jared Kaplan, Esq.Jared Kaplan, University of California at Los Angeles (A.B. 1960), Harvard University (LL.B. 1963); member, Illinois Bar. Past Chairman, Legislative and Regulatory Advisory Committee, The ESOP Association.
ESOPs (Portfolio 354) Yoram Keinan, Esq.Yoram Keinan, B.A., LL.B., Tel Aviv University; LL.M. (Taxation), Hebrew University; M.B.A., Bar Ilan University; M.P.A., LL.M. (International Taxation), Harvard University; LL.M. (Taxation), J.S.D., University of Michigan. As Counsel with Greenberg Traurig, Mr. Keinan specializes in United States taxation of financial products and institutions and represents major investment banks and financial institutions in the United States. Prior to joining Greenberg Traurig, Mr. Keinan was with Ernst & Young's National Tax Department in Washington, D.C. Before that, Mr. Keinan practiced with Shearman & Sterling and with Ernst & Young's tax department in Israel. He has authored numerous articles and has taught Harvard's International Tax Program, Kennedy School of Government, and School of Arts and Sciences (Department of Economics).
Accounting for Debt Instruments (Liabilities) (Portfolio 5105)The Economic Substance Doctrine (Portfolio 508) David I. Kempler, Esq.David I. Kempler, J.D., 1966, University of Connecticut; LL.M., 1967, The George Washington University Law School, taxation; B.S., 1963
University of Pennsylvania. Mr. Kempler is admitted to Connecticut, District of Columbia and the United States Supreme Court. He focuses his practice on corporate tax, business planning and not-for-profit (especially in the health care area) tax matters. He advises clients on a broad range of tax issues involving mergers and acquisitions, closely held entities, joint ventures and planning for health care entities. David is editor of the Corporate Tax and Business Planning Review and has written many articles in the tax area. He is a frequent speaker at tax conferences and is a member of the Corporate Relationships and Exempt Organizations Committee of the American Bar Association Section of Taxation. In 2006, he was selected by his peers for inclusion in The Best Lawyers in America. He is affiliated with the District of Columbia Bar, Federal Bar Association and the American Bar Association.
Boot Distributions and Assumption of Liabilities (Portfolio 782) Kathryn J. KennedyKathryn J. Kennedy; Drake University (B.S., with honors, 1974); Fellow of the Society of Actuaries (F.S.A., 1976); Northwestern University School of Law (summa cum laude, Order of the Coif, Article Editor for the Northwestern University Law Review, 1980); Professor of Law and Director of the Center for Tax Law and Employee Benefits, John Marshall Law School; member of the ABA Section of Taxation; former chair of the ISBA Employee Benefits Section Council; chair of the CBA Employee Benefits Committee.
IRAs (Portfolio 367)SEPs and SIMPLEs (Portfolio 368) Barbara L. Kirschten, Esq.Barbara L. Kirschten, B.A., University of Pennsylvania (summa cum laude); Honours B.A., Cambridge University; Ph.D., M.A., Harvard University; J.D., Northwestern University; member, New York and District of Columbia Bars; former member, Steering Committee District of Columbia Bar Association Taxation Section and former Chair, Exempt Organizations Committee; Co-Chair, Subcommittee on Museums of Other Cultural Organizations, Exempt Organizations Committee, ABA Section of Taxation; author, The Nonprofit Corporation Forms Handbook; co-author, Federal and State Taxation of Exempt Organizations.
Charitable Contributions: Income Tax Aspects (Portfolio 521)Charitable Contributions: Income Tax Aspects (Portfolio 863) James P. Klein, Esq.James P. Klein, J.D., Columbia University Law School (1972), LL.M. in taxation, New York University Law School (1979), B.A., Fordham University (1968); member, New York State Bar; member, past chair, Employee Benefits Committee, Section of Taxation, American Bar Association; member, past chair, Employee Benefits Committee, Tort and Insurance Section, American Bar Association; member, Tax Management Advisory Board; founding member and past chair, International Pension and Employee Benefits Lawyers Association (IPEBLA).
International Pension Planning (Portfolio 320) Michael J. Kliegman, Esq.Michael J. Kliegman, A.B., University of Pennsylvania; J.D., Boston University School of Law, LL.M. (Taxation), Georgetown University Law Center; member: American Bar Association, Tax Section (Corporate Tax Committee; Task Force on Acquisitions Involving S Corporations); New York State Bar Association, Tax Section (Committee on Reorganizations); formerly, Internal Revenue Service, Office of Chief Counsel, Reorganization Branch (1981–85), Group Chief (1984–85).
Single Entity Reorganizations: Recapitalizations and F Reorganizations (Portfolio 774) Steven E. KligSteven E. Klig, B.A. (cum laude), C.U.N.Y., Queens College; J.D. (cum laude), Fordham University School of Law; LL.M. (Taxation), New York University School of Law; member, American Bar Association and the New York State Bar Association and their respective Tax Sections; admitted to practice in New York, Colorado, Connecticut, and the District of Columbia; speaker, various conferences including the American Bar Association and the Bank Tax Institute; author, various articles in NYU Institute of Taxation, Tax Management Memorandum, and Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures, & Other Strategic Alliances (Practising Law Institute).
Partnerships — Taxable Income; Allocation of Distributive Shares; Capital Accounts (Portfolio 712) George C. Koutouras, Esq.George C. Koutouras, LL.M. (Taxation), Georgetown University Law Center; J.D., University of Detroit School of Law; B.S.A., University of Michigan; bar membership, Michigan and Illinois; formerly Attorney/Advisor to Special Trial Judge Stanley J. Goldberg, United States Tax Court; Co-Author, 767-2nd T.M., Redemptions and 564 T.M., Related Party Transactions; Adjunct Professor, University of Illinois Urbana-Champaign Master of Tax Program.
Related Party Transactions (Portfolio 564)Redemptions (Portfolio 767)Stock Sales Subject to Section 304 (Portfolio 768)Boot Distributions and Assumption of Liabilities (Portfolio 782) Michael G. Kushner, Esq.Michael G. Kushner, B.A., George Washington University (1974); J.D., University of Virginia School of Law (1977); LL.M. (Taxation), George Washington University (1982). Co-author, The Employee Benefits Desk Encyclopedia (BNA Books, 1995); Retirement & Welfare Benefit Plans (BNA Books, 1989); co-editor, ERISA, The Law and the Code (BNA Books); co-editor, ERISA Regulations (BNA Books). Member, District of Columbia, Maryland and Virginia Bars. Adjunct faculty member, Georgetown University Certified Employee Benefits Specialist Program (1982-88); adjunct faculty member, The Dickinson College School of Law (1989-91).
Multiemployer Plans — Special Rules (Portfolio 359)Reporting and Disclosure Under ERISA (Portfolio 361)
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Howard J. Levine, Esq.Howard J. Levine, B.A., Hunter College (1969); J.D., State University of New York at Buffalo (cum laude, 1972); LL.M. (Taxation), Georgetown University Law Center (1976); attorney and assistant branch chief, Office of Chief Counsel, Internal Revenue Service (1972-1976); adjunct lecturer in Real Estate Taxation, American University Law School (1980-1982); adjunct professor, The George Washington University Law School and Georgetown University Law Center LL.M. Tax Programs (1982-1993); contributing editor, The Journal of Real Estate Taxation; Tax Management Distinguished Author (2000); member, Advisory Board, Tax Management International Journal; member, Advisory Board, CCH Journal of Taxation of Global Transactions; author, 936 T.M., U.S. Income Tax Treaties — The Limitation on Benefits Article; partner, Roberts & Holland LLP, Washington, D.C. and New York, N.Y.; member, American Bar Association (Chairman, Committee on Sales, Exchanges and Basis, and Subcommittee Chairman, Like Kind Exchanges, Tax Section 1990-1994), New York Bar, District of Columbia Bar, International Fiscal Association.
U.S. Income Tax Treaties — The Limitation on Benefits Article (Portfolio 936) Richard A. Levine, Esq.Richard A. Levine, B.S., Economics, University of Pennsylvania (1964); J.D., Harvard Law School (1967); L.L.M., New York University (1968); member, New York, U.S. Tax Court, Court of Federal Claims, U.S. Supreme Court, U.S. Court of Appeals (Second Circuit), U.S. District Court, and Southern and Eastern Districts of New York Bars; editor, Harvard Law Review, 1965-1967; editor-in-chief, Roberts & Holland, Annotated Tax Forms — Practice and Procedure (3d ed.); co-author, “Tax Court's Revised and Expanded Partnership Rules Leave Questions Open,” 69 Journal of Taxation 164 (Sept. 1988); member, The Association of the Bar of the City of New York, New York State and American Bar Associations (Sections on Taxation; Litigation); contributor, Journal of Taxation and other tax periodicals.
Tax Court Litigation (Portfolio 630) Jack B. Levy, Esq.Jack B. Levy, Partner, Balch and Bingham LLP, Birmingham, AL; New York University School of Law, LL.M., in Taxation, 1977; Emory Law School, J.D., 1976; Emory University, B.A., 1973. He is admitted to Alabama and Georgia. Mr. Levy concentrates his practice in the areas of employer resources, employee benefits and executive compensation, corporate and business, health care, taxation and estate and trust planning. He represents numerous closely held businesses, professionals and professional corporations and negotiates and closes sales of professional practices and closely held business practices. He also lectures on issues relating to pension and welfare benefits as well as health care matters. He is listed in The Best Lawyers in America, 1995 Edition - Present (Employee Benefits Law); 2007 Edition (Corporate Law); 2008 Edition (Healthcare Law), and is a member of the American Health Lawyers Association; Southern Employee Benefit Conference; American Bar Association, Tax Section; Alabama State Bar, Tax Section; Alabama Profit Sharing Council; Alabama Super Lawyers, 2009.
Employee Benefits for Small and Mid-Sized Employers (Portfolio 353) Henry J. Lischer, Jr.Henry J. Lischer, Jr., University of Iowa (B.B.A., 1967; J.D., 1970); New York University (LL.M. in Taxation, 1974); Judge Advocate, U.S. Marine Corps, 1970–73; Associate, Lillick, McHose & Charles, Los Angeles, California, 1974–75; Professor of Law, University of Alabama, 1975–78; Professor of Law, Southern Methodist University, 1978–present; Counsel, Malouf Lynch Jackson & Swinson, Dallas, Texas, 1982–84, 1985–present; Professor-in-Residence, Office of Chief Counsel, Internal Revenue Service, Washington, D.C., 1984–85; Fellow, American College of Tax Counsel; Academic Fellow, American College of Trust and Estate Counsel.
Incomplete Lifetime Transfers: Retained Powers Under Sections 2036(a)(2) and 2038 (Portfolio 50)Incomplete Lifetime Transfers: Retained Beneficial Interests Under Sections 2036(a)(1) and 2037 (Portfolio 52)Gifts (Portfolio 845)Gifts to Minors (Portfolio 846) Peter A. Lowy, Esq.Peter A. Lowy, J.D. (cum laude and member of law review), Tulane Law School; L.L.M. (taxation), New York University School of Law; member: New York and Texas bars; currently: Senior Tax Counsel, Shell Oil Company; formerly: Senior Tax Attorney, Exxon Mobil Corporation; attorney-advisor, the Honorable Maurice Foley, United States Tax Court; judicial clerk, the Honorable Nauman Scott, U.S. District Court; adjunct professor in Legal Research & Writing, University of Houston Law.
U.S. Federal Tax Research (Portfolio 100)
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Ewing W. Madole, Esq.Ewing W. Madole, B.A., M.B.A. Mississippi State University (1973, 1975); J.D., Columbia University School of Law (1985); LL.M. in Taxation, New York University (1990); Member of the New York Bar; Certified Public Accountant, Tennessee (1977).
Controlled Foreign Corporations — Section 956 (Portfolio 929) Kirk F. Maldonado, Esq.Kirk F. Maldonado, B.A., University of Nebraska at Omaha (1975); J.D., Creighton University (1978); M.L.T., Georgetown University (1981); member, California Bar; Attorney, Employee Plans and Exempt Organizations Division, Office of Chief Counsel, Internal Revenue Service (1978-1981).
Securities Law Aspects of Employee Benefit Plans (Portfolio 362) Peter J. Marathas, Jr. Esq.Peter J. Marathas, Jr., B.A. (1981), cum laude, M.A. (1986), summa cum laude, Bradley University; J.D., magna cum laude, University of Illinois, Harno Fellow (1994); Employment and Labor Section, American Bar Association; Boston Bar Association; Massachusetts Bar (1997), Illinois Bar (1994), Florida Bar (2005).
ERISA — Litigation, Procedure, Preemption and Other Title I Issues (Portfolio 374) Steven R. Mather, Esq.Steven R. Mather, University of Iowa (B.B.A. with highest distinction 1978; J.D., with distinction 1982); Member, California and Iowa Bars; Certified Public Accountant, Iowa, 1979; Senior Attorney, District Counsel, Internal Revenue Service, Los Angeles 1983–87; Co–Director, Tax Court Pro Se Program (Los Angeles/Beverly Hills) 1988–Present; Lecturer, Federal Tax Procedure, Golden Gate University Masters in Taxation Program; Member, Section of Taxation of California, Los Angeles County and Beverly Hills Bar Associations; Contributor, The Tax Lawyer; Co–author: 638-2nd T.M., Federal Tax Collection Procedure.
Audit Procedures for Pass-Through Entities (Portfolio 624)Federal Tax Collection Procedure — Liens, Levies, Suits and Third Party Liability (Portfolio 637)Federal Tax Collection Procedure — Defensive Measures (Portfolio 638) Thomas J. Matragrano, CPAThomas J. Matragrano, J.D., Hofstra University School of Law; B.A., State University of New York at Stony Brook; member, New York State Bar and Tax Section, New York State Bar Association; formerly Attorney/Advisor, Office of Chief Counsel, Internal Revenue Service.
Redemptions (Portfolio 767) James E. MauleJames Edward Maule, B.S., University of Pennsylvania (1973); J.D., Villanova University (1976); LL.M. (Taxation), George Washington University (1979); lecturer, Villanova University Graduate Tax Program and Tax Forum CLE Programs; lecturer, Philadelphia Bar Association Tax Section; member, Advisory Board on U.S. Income, Tax Management Inc.; former attorney-advisor, United States Tax Court, Judge Herbert L. Chabot; former attorney-advisor, Chief Counsel to the Internal Revenue Service; former Editorial Advisory Board member and Columnist, Journal of Limited Liability Companies; former lecturer, ALI-ABA; former lecturer, Tax Management Inc. & Continuing Legal Education Satellite Network; former lecturer, Pennsylvania Bar Institute; former lecturer, Georgetown University Law Center Institute on State and Local Taxation; former lecturer, The Dickinson School of Law CLE Programs; member, American Bar Association, Section of Taxation, Committee on S Corporations (Consultant and former Chair, Subcommittee on Subchapter S and State Law; former Chair, Subcommittee on Comparison of Partnerships and S Corporations).
Gross Income: Overview and Conceptual Aspects (Portfolio 501)Gross Income: Tax Benefit, Claim of Right and Assignment of Income (Portfolio 502)Deductions: Overview and Conceptual Aspects (Portfolio 503)Deduction Limitations: General (Portfolio 504)Trade or Business Expenses and For-Profit Activity Deductions (Portfolio 505)Tax Credits: Concepts and Calculation (Portfolio 506)Income Tax Liability: Concepts and Calculation (Portfolio 507)State, Local, and Federal Taxes (Portfolio 525)Depreciation: MACRS and ACRS (Portfolio 531)Income Tax Basis: Overview and Conceptual Aspects (Portfolio 560)Tax Incentives for Economically Distressed Areas (Portfolio 597)State Taxation of S Corporations (Portfolio 1510) Todd F. Maynes, Esq.Todd F. Maynes, B.A., magna cum laude, Brigham Young University (1984); J.D., magna cum laude, Brigham Young University (1987); law clerk to Judge Kenneth Ripple, United States Court of Appeals for the Seventh Circuit (1987–1988); partner, Kirkland & Ellis LLP, Chicago, Illinois, since 1988; adjunct professor, Chicago-Kent College of Law, Graduate Tax Program, since 1993; chair, Planning Committee of the Chicago-Kent College of Law, Federal Tax Institute.
Start-Up Expenditures (Portfolio 534) Todd Y. McArthur, Esq.Todd Y. McArthur, B.S., University of Virginia, McIntire School of Commerce (1985), Beta Alpha Psi; J.D., University of Virginia, School of Law (1990). Author, Selected Federal Income Tax Issues Arising in Technology Ventures and Business Transactions Involving Technology or Facilitated by the Internet — A Transactional Perspective; with Steven R. Lainoff, “The Final Functional Currency Regime for U.S. Taxpayers Operating in Hyperinflationary Environments: Mandatory DASTM”, 12 Tax Management Int'l J. 583 (1994). Member, Virginia State Bar, District of Columbia Bar, United States Tax Court, and American Bar Association.
Partnership Transactions — Section 751 Property (Portfolio 720) John C. McCoy, Esq.John C. McCoy, B.B.A., University of Notre Dame (1969); J. D., high honors, George Washington University (1976); Arent Fox, LLP since 1976, member since 1984; member, District of Columbia, Virginia, Maryland and American Bar Associations.
Loss Deductions (Portfolio 527)Bad Debts (Portfolio 538) Louis A. Mezzullo, Esq.Louis A. Mezzullo, University of Maryland (B.A. 1967, M.A. 1976), University of Richmond (J.D. 1976); Partner, Luce, Forward, Hamilton & Scripps LLP, 2006 to present; Partner, McGuireWoods LLP, Richmond, Virginia, 2003 to 2006; Member, Mezzullo & Guare, PLC, Richmond, Virginia, 2000 to 2003; Founding Member, Mezzullo & McCandlish, Richmond, Virginia, 1982 to 2000; Adjunct Professor, University of Miami School of Law, University of Richmond Law School.
Fellow and Chair, American College of Tax Counsel; Fellow and former Regent, American College of Trust and Estate Counsel; Charter Fellow, American College of Employee Benefits Counsel; Past Chair, ABA Section of Real Property, Probate and Trust Law (2000-01); former Member of Council, and Current Chair of the Business Planning Subcommittee of the Estate and Gift Taxes Committee of the ABA Section of Taxation; and Academician and Vice President, International Academy of Trust and Estate Law.
Author, An Estate Planner's Guide to Buy-Sell Agreements; An Estate Planner's Guide to Life Insurance; An Estate Planner's Guide to Qualified Retirement Plan Benefits; An Estate Planner's Guide to Family Business Entities; and Valuation Rules Under Chapter 14, all published by the American Bar Association, and Limited Liability Companies in Virginia, published by the Virginia Law Foundation; Co-author, Advising the Elderly Client, published by Clark, Boardman, Callaghan.
The Migrant Client: Tax, Community Property, and Other Considerations (Portfolio 803)Estate Planning for Owners of Closely Held Business Interests (Portfolio 809)Family Limited Partnerships and Limited Liability Companies (Portfolio 812)Estate and Gift Tax Issues for Employee Benefit Plans (Portfolio 814)Valuation of Corporate Stock (Portfolio 831)Transfers of Interests Family Entities Under Chapter 14: Sections 2701, 2703 and 2704 (Portfolio 835)Estate and Gift Tax Issues for Employee Benefit Plans (Portfolio 378)Family Limited Partnerships and Limited Liability Companies (Portfolio 722) Forrest David Milder, Esq.Forrest David Milder, S.B., Massachusetts Institute of Technology (1973) (Phi Beta Kappa); S.M., Massachusetts Institute of Technology (1974); J.D., Harvard Law School (1977); LL.M. (Taxation), Boston University (1983); admitted to bar, Massachusetts; member, Tax Section, American Bar Association, Boston Bar Association (Chairman, Internet and Computer Assisted Tax Practice Committee, former Chairman, Section of Law Office Management and Professionalism); member, National Association of Bond Lawyers; Boston University School of Law, Instructor of Legal Research and Writing; Lecturer, Federal Tax Institute, Massachusetts Continuing Legal Education, Massachusetts Association of Public Accountants, Northwest Center for Professional Education; Contributor on tax matters to The Wall Street Journal, Boston Globe, Massachusetts Banker and Tradesman, The Matrimonial Strategist, Massachusetts Lawyer's Weekly, and Writer's Digest; author of “Disposition of Personal Residence” (The Best of MCLE, August 1991). Contributed Chapter “Federal Income Taxation of Asset Securitization Transactions” to Securitization: Asset–Backed and Mortgage–Backed Securities (Michie 1994).
Rehabilitation Tax Credit and Low-Income Housing Tax Credit (Portfolio 584) Joel E. Miller, Esq.Joel E. Miller, A.B., Columbia College (1954); J.D., Columbia University School of Law (1956); LL.M. in Taxation, New York University Graduate School of Law (1964); Law Secretary to Honorable Harold R. Medina, Judge, U.S. Court of Appeals for the Second Circuit, 1956–1957; associated with Paul, Weiss, Rifkind, Wharton & Garrison, New York, N.Y., 1957–1960; associated with and member of Demov, Morris, Levin & Shein, New York, N.Y., 1961–1969; member of adjunct and full-time faculty, St. John's University School of Law between 1976 and 1989; Chair, Subcommittee on Condominiums and Cooperatives, Committee on Real Estate Tax Problems, Section of Taxation, American Bar Association; Chair, Subcommittee on Liens, Cooperatives and Condominiums Committee, Real Property Law Section. New York State Bar Association, Tax Section; co-author, Modern Trust Forms and Checklists (Warren, Gorham & Lamont, Inc. 1980); author, Federal Taxation of Trusts (Prentice-Hall, Inc., 1968); contributor to Tax Law Review, Journal of Real Estate Taxation, Journal of Taxation and other legal publications on matters involving federal taxation and property law; editor, Real Estate Tax Ideas 1979–1983; member, several advisory boards; and lecturer at various tax institutes. Note: Portions of this portfolio are taken from articles written by Mr. Miller and originally published in the Journal of Real Estate Taxation (Warren, Gorham & Lamont, Inc.).
Cooperative and Condominium Apartments (Portfolio 596) Anne E. Moran, Esq.Anne E. Moran, Partner, Steptoe & Johnson, LLP; B.A., Wellesley College; J.D., Harvard Law School; formerly Tax Counsel, United States Senate Committee on Finance; former member of the ERISA Advisory Council for the United States Department of Labor; member, American Bar Association, Section of Taxation; member, American Bar Association, Joint Committee on Employee Benefits (former chair); member, District of Columbia Bar, Tax Section, Committee on Employee Benefits (former chair) and Steering Committee (former member); member, American College of Employee Benefits Counsel (former board member).
Reasonable Compensation (Portfolio 390)
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Andrew W. Needham, Esq.Andrew W. Needham, J.D., Georgetown University Law Center; LL.M. (Taxation), Georgetown University Law Center; M.B.A., The Wharton School; B.A., University of Arizona; Member, Executive Committee, Tax Section of New York State Bar Association, American Bar Association, United States Tax Court.
Private Equity Funds (Portfolio 735)Hedge Funds (Portfolio 736) Annette NellenAnnette Nellen (B.S., CSU, Northridge; MBA, Pepperdine University; J.D. Loyola Law School) is a Professor of Accounting & Taxation in the College of Business at San José State University, and a Fellow with the New America Foundation.
Amortization of Intangibles (Portfolio 533) Caroline H. Ngo, Esq.Caroline H. Ngo, B.S., University of Virginia (2002); J.D., Cornell Law School (2005); Associate, McDermott Will & Emery LLP (2005-present); member, New York and District of Columbia Bars.
Accumulated Earnings Tax (Portfolio 796)
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Paul W. Oosterhuis, Esq.Paul W. Oosterhuis, B.A., Brown University (1969); J.D., Harvard University (1973); member, Tax Management U.S. Income Advisory Board; member, International Fiscal Association; member, Special Committee on International Tax Policy, U.S. Chamber of Commerce; member, American Bar Association, Section on Taxation, Committee on Foreign Activities of U.S. Taxpayers; Adjunct Professor, Georgetown University Law Center (1977-1983); Legislation Attorney (1973-1977) and Legislation Counsel (1977-1978), Joint Committee on Taxation, U.S. Congress; member, District of Columbia Bar Association.
Research and Development Expenditures (Portfolio 556)
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Jeffrey H. Paravano, Esq.Jeffrey H. Paravano, B.S.B.A., cum laude, John Carroll University; J.D., magna cum laude, Georgetown University Law Center; LL.M. in Taxation, with distinction, Georgetown University Law Center; Firmwide Chair of Baker & Hostetler LLP's Tax, Personal Planning and Employee Benefits Group; formerly, Senior Advisor to the Assistant Secretary, Tax Policy, Department of Treasury; adjunct professor of law (LL.M. program), Case Western Reserve University School of Law and Georgetown University Law Center; member, American Bar Association, Section of Business Law and Section of Taxation; soon-to-be Chair, ABA Tax Section's Affiliated and Related Corporations Committee; former member, Editorial Advisory Boards of Corporate Business Taxation Monthly and The Tax Adviser; Chair, Cleveland International Tax Forum; Editor in Chief, The Tax Lawyer; President, Tax Club; frequent author and speaker on tax topics. Admitted to practice in New York, Connecticut, Ohio, Colorado, Maryland, and Washington, D.C.
Tax Shelters (Portfolio 798) Gordon O. Pehrson, Jr. Esq.Gordon Pehrson, a partner in the Washington office of Hopkins & Sutter, is a nationally recognized expert on the taxation of insurance companies and their products. Mr. Pehrson is a graduate of the College of William & Mary (A.B. 1964) and the University of Michigan School of Law (J.D. cum laude 1967), where he was elected to the Order of the Coif. From 1977 through 1981, Gordon was an adjunct professor of law in the graduate tax program at Georgetown University. In 1990, he was elected as a member of the American Law Institute.
Annuities, Life Insurance, and Long-Term Care Insurance Products (Portfolio 546) Dennis L. Perez, Esq.Dennis L. Perez, A.B., San Diego State University (1978); J.D., University of California at Los Angeles (1982). Trial Attorney, District Counsel, Internal Revenue Service (1982–1986). Member: American Bar Association, State Bar of California. Principal – Hochman, Salkin and DeRoy, P.C., Beverly Hills, California.
Tax Crimes (Portfolio 636) Theodore D. Peyser, Esq.Theodore D. Peyser, B.A., Princeton University (1950); LL.B., Yale Law School (1955); member, District of Columbia, Tax Court, Court of Federal Claims, Federal Circuit, and U.S. Supreme Court Bars; member, Court Procedure Committee, Tax Section, ABA; Tax Division, U.S. Department of Justice, trial attorney (1955-1973), chief, Claims Court Section (1974-1984), Special Litigation Counsel (1985-1987); author, 631-2nd T.M., Refund Litigation and 628-2nd T.M. Transferee Liability; co-author, 630-3rd T.M. Tax Court Litigation; contributor, Tax Practice Series.
Limitations Periods, Interest on Underpayments and Overpayments, and Mitigation (Portfolio 627)Transferee Liability (Portfolio 628)Refund Litigation (Portfolio 631)Tax Court Litigation (Portfolio 630) Barnet Phillips, IV Esq.Barnet Phillips, IV, Partner, Skadden, Arps, Slate, Meagher & Flom L.L.P., New York, New York; B.A., Yale University 1970; J.D., Fordham University 1973; LL.M., New York University 1977.
Structuring Corporate Acquisitions — Tax Aspects (Portfolio 770) David W. Powell, Esq.David W. Powell, B.B.A., cum laude, Southern Methodist University (1979); J.D., University of Texas School of Law (1982); member: Tax section of the American Bar Association, District of Columbia Bar, New York State Bar, State Bar of Texas, Louisiana State Bar; Certified Public Accountant, Louisiana (1983).
Church and Governmental Plans (Portfolio 372)
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Thomas Z. Reicher, Esq.Thomas Z. Reicher, Amherst College (B.A. summa cum laude and Phi Beta Kappa, 1970); University of California at Berkeley (M.A. 1973); Stanford University Law School (J.D. 1976); member, Connecticut Bar; Director, New England Employee Benefits Council; partner, Day, Berry & Howard.
Statutory Stock Options (Portfolio 381)Reductions Force (Portfolio 398) Richard Reichler, Esq.Mr. Reichler was formerly an Attorney Advisor, Office of the Chief Counsel Internal Revenue Service in Washington, D.C. and Vice President, Tax Planning and Services and Deputy General Counsel, of the Long Island Lighting Company. He also acted as the National Director of Executive Compensation Planning while a Senior Tax Partner at Ernst & Young, P.C.'s New York office. He is currently with the law firm of Meltzer, Lippe, Goldstein & Breitstone, LLP. Mr. Reichler is a 1955 graduate of Columbia College and a 1957 graduate of Columbia University Law School. He is a member of the New York State Bar Association (Tax Section), the International Fiscal Association, and the BNA Tax Management Advisory Board. Mr. Reichler is the author of “Leveraged Buyout Financing in Business Combinations and Restructuring,” and “The Limited Partnership as an Investment Vehicle.”
State Taxation of Compensation and Benefits (Portfolio 366)State Taxation of Compensation and Benefits (Portfolio 1750) Taylor S. Reid, Esq.Taylor S. Reid, Esq., B.A., University of California at Berkeley (1986); Graduate Diploma in International Studies, University of Vienna, Austria (1990); J.D., Northwestern University School of Law (1993, cum laude); Partner, Baker & McKenzie LLP; co-author, Internet Law for the Business Lawyer (ABA: 2001); co-author, United States Taxation of Income Derived from International Electronic Commerce Transactions, Tax Management Memorandum (December 4, 2000); member, State Bar of California, Illinois State Bar Association, American Bar Association Section on Taxation.
Federal Taxation of Software and E-Commerce (Portfolio 555) Charles P. Rettig, Esq.Charles P. Rettig, B.A., University of California at Los Angeles (1978); J.D., Pepperdine University (1981); LL.M., New York University (1982). Member: American Bar Association, State Bar of California, State Bar of Arizona. Principal – Hochman, Salkin and DeRoy, P.C., Beverly Hills, California.
Tax Crimes (Portfolio 636) Donald B. Reynolds, Jr. Esq.
Donald B. Reynolds, Jr., shareholder, Buchanan Ingersoll & Rooney PC; J.D., magna cum laude, 1979, Georgetown University Law Center; senior case and note editor, Law and Policy in International Business; B.A., magna cum laude, 1976, Hamilton College. Mr. Reynolds focuses his practice on financings, acquisitions and business planning for a variety of businesses, including both closely and widely held entities. His clients include mortgage companies, real estate brokerage firms, insurance companies and real estate developers. Reynolds specializes in tax and business and international tax. He is admitted to District of Columbia. Mr. Reynolds has represented the largest privately-held real estate brokerage firm in the country in virtually all of its significant acquisitions and financings. In addition to the brokerage business, the client's subsidiaries operate mortgage, title insurance and casualty insurance businesses. Along with his transactional work, Don also specializes in tax planning for partnerships, limited liability companies and S corporations and is a frequent contributor to tax publications and tax conferences.
Tax Shelters (Portfolio 798) Candace A. Ridgway, Esq.Candace A. Ridgway, B.A. (cum laude), University of Connecticut; M.B.A., Arizona State University; J.D. (magna cum laude), Cornell Law School; LL.M. (Taxation, with distinction), Georgetown University Law Center; member, District of Columbia Bar; member, New York State Bar; member, American Bar Association, Tax Section, Corporate Tax Committee.
Corporate Bankruptcy (Portfolio 790)Corporate Separations (Portfolio 776)Corporate Acquisitions — D Reorganizations (Portfolio 772) Jeffrey I. Rosenberg, Esq.Jeffrey I. Rosenberg, undergraduate degree, University of Rhode Island; J.D., Western New England College School of Law; LL.M. in Taxation, Georgetown University Law Center; formerly Attorney-Advisor, Passthroughs and Special Industries Division of the Office of Chief Counsel, Internal Revenue Service; speaker and lecturer, various tax institutes; author, various articles on tax issues in partnership area.
Limited Liability Companies (Portfolio 725) Howard J. Rothman, Esq.Howard J. Rothman, B.A., City College of New York (1967); J.D., Brooklyn Law School (1971); LL.M., New York University School of Law (1972); member, American Bar Association, Section of Taxation, Committee on Corporate Tax; member, New York State Bar Association, Section of Taxation, Committee on Corporations, Committee on Partnerships, and Committee on Income from Real Property; member, International Bar Association, Committee on Taxation; Advisory Board, Tax Management Real Estate Journal; member, New York State Bar; co-author, Tax Management Portfolios No. 561, Capital Assets and No. 759, Transfers to Controlled Corporations: Related Problems.
Capital Assets (Portfolio 561)Transfers to Controlled Corporations: General (Portfolio 758)Transfers to Controlled Corporations: Related Problems (Portfolio 759) Robert P. Rothman, Esq.Robert P. Rothman, Of Counsel, Piper Rudnick L.L.P., New York, New York; B.S., Cornell University 1978; J.D., Columbia University 1981; Formerly associated with Skadden, Arps, Slate, Meagher & Flom L.L.P., New York, New York.
Structuring Corporate Acquisitions — Tax Aspects (Portfolio 770)
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Michael H. Salama, Esq.Michael H. Salama, B.S. (Mathematics), Vassar College (Ford Foundation Scholar); J.D. (with honors), George Washington University Law School. Vice President Tax Administration & Senior Tax Counsel for The Walt Disney Company. Previous positions include: senior manager, the Washington National Tax Services group, PricewaterhouseCoopers LLP; senior trial attorney, Office of Chief Counsel, IRS Active member of the American Bar Association's Tax Accounting Committee. Previous professional organization activities include: Chair, Los Angeles County Bar Association's Entertainment Tax Committee; member, IRS Commissioner's Advisory Council; member, Georgetown University State & Local Tax Institute Advisory Board; member, UCLA Tax Controversy Institute Planning Committee.
Film Production: Basis Recovery and Federal Incentives (Portfolio 599) Bruce S. Schaeffer, Esq.Bruce S. Schaeffer, Master of Laws (Taxation), New York University School of Law, 1976; J.D., Brooklyn Law School, 1975. Mr. Schaeffer is an attorney in private practice with offices in New York, N.Y. He concentrates his practice in the areas of estate planning, taxation, franchising, and securities fraud. Mr. Schaeffer is also president of Franchise Valuations Limited and is a member of the Institute of Business Appraisers.
Tax Aspects of Franchising (Portfolio 559) J. Ronald SchiffJ. Ronald Shiff, B.S., University of Maryland; J.D., Georgetown University Law Center; LL.M. Taxation, Georgetown University Law Center; Adjutant Professor of Law, University of Baltimore; Member, The Bar Association of Baltimore City (Chair, Budget & Finance Committee); Maryland State Bar Association (Section of Taxation, Past Chairman); American Bar Association (Tax Section, Corporate Tax Committee, Regulated Investment Company Committee); author of various tax articles.
David M. SchizerDavid M. Schizer is the Dean and Lucy G. Moses Professor of Law at Columbia Law School, where he teaches courses on federal income taxation, the taxation of financial instruments, corporate tax, and the economics of transactions. His publications include: “Frictions and Tax-Motivated Hedging: An Empirical Exploration of Publicly-Traded Exchangeable Securities,” 56 National Tax J. 167 (Mar. 2003) (with William Gentry); “Understanding Venture Capital Structure: A Tax Explanation for Convertible Preferred Stock,” 116 Harv. L. Rev. 874 (2003) (with Ronald Gilson); “Reducing the Tax Cost of Indexed Options,” 96 Tax Notes 1375 (9/2/02); “Frictions as a Constraint on Tax Planning,” 102 Colum. L. Rev. 1312 (2001); “Tax Constraints on Indexed Options,” 149 U. Pa. L. Rev. 1941 (2001); “Sticks and Snakes: Derivatives and Curtailing Aggressive Tax Planning,” 73 S. Cal. L. Rev. 1339 (2000); “Executives and Hedging: The Fragile Legal Foundation of Incentive Compatibility,” 100 Colum. L. Rev. 440 (2000); and “Realization as Subsidy,” 73 N.Y.U. L. Rev. 1549 (1998). Dean Schizer has also written several reports for the New York State Bar Association, where he serves on the executive committee and as co-chair of the Committee on Financial Institutions. Dean Schizer is also a member of the Tax Club and the Tax Forum. He served in the tax department at Davis Polk & Wardwell from 1995-98, and clerked for Justice Ruth Bader Ginsburg during the U.S. Supreme Court's October 1994 term. He is a graduate of Yale College and Yale Law School.
Financial Instruments: Special Rules (Portfolio 186) John G. Schmalz, Esq.John G. Schmalz, B.A., University of Wisconsin, Milwaukee; J.D., Marquette University; formerly Attorney-Advisor, Legislation and Regulations Division, Office of the Chief Counsel, Internal Revenue Service; member, American Bar Association, Tax Section (Partnership Committee), State Bar of Wisconsin; Vice Chairman, ABA Partnership Tax Committee's Subcommittee on like-kind exchanges; author, articles published in Journal of Partnership Taxation, Journal of Taxation, Journal of Real Estate Taxation, and Journal of S Corporation Taxation.
Limited Liability Companies (Portfolio 725) John W. Schmehl, Esq.John W. Schmehl, B.A., Muhlenberg College (cum laude, 1975); J.D., Dickinson School of Law (cum laude, 1978); Editor, Dickinson Law Review; LL.M. (Taxation), Temple University School of Law (1982); former Trial Attorney, Office of Chief Counsel, Internal Revenue Service; author and lecturer on various tax topics concerning corporate tax and tax procedure.
Compelled Production of Documents and Testimony Tax Examinations (Portfolio 633)Responsible Person and Lender Liability for Trust Fund Taxes — Sections 6672 and 3505 (Portfolio 639) Mark N. Schneider, Esq.Mark N. Schneider, B.S., Lehigh University, magna cum laude (1971); M.B.A., Columbia University (1973). Certified Public Accountant (California, DC, New York and Texas); Partner, Deloitte Tax LLP; member, American Institute of Certified Public Accountants, National Association of Real Estate Investment Trusts, American Society of Pension Professionals & Actuaries; AICPA Tax Practice Responsibilities Committee; and former member of the AICPA Employee Benefits Tax Committee.
Real Estate Investment Trusts (Portfolio 742) Daniel J. Schwartz, Esq.Daniel J. Schwartz, University of Missouri at Columbia (A.B. 1974 cum laude); University of Missouri at Kansas City (J.D. 1977); Member of the Bar Association of Metropolitan St. Louis, the Missouri Bar, and the American Bar Association Section of Taxation, Committee on Employee Benefits.
Employee Benefits for Tax-Exempt Organizations (Portfolio 373) David H. ShapiroDavid H. Shapiro, A.B., cum laude, Princeton University (1992); J.D., University of Virginia School of Law (1995); LL.M. (Taxation), New York University School of Law (1997). Editor, Virginia Tax Review (1994-95); Graduate Editor, Tax Law Review (1996-97). Adjunct Professor of Law, Georgetown University Law Center. Member: New York State Bar, District of Columbia Bar, American Bar Association (Tax Section) and District of Columbia Bar Association (Tax Section).
Taxation of Equity Derivatives (Portfolio 188) Daniel N. ShaviroDaniel N. Shaviro, A.B., Princeton University (1978); J.D., Yale Law School (1981); member, District of Columbia Bar; author of various books including When Rules Change: A Political and Economic Analysis of Retroactivity and Transition Relief and Making Sense of Social Security Reform; contributor of articles to various journals including Tax Law Review, Virginia Tax Review, TAXES, Harvard Law Review, University of Chicago Law Review, and Michigan Law Review; Caplin & Drysdale, Washington D.C. (1981–84); Legislation Attorney, Joint Committee on Taxation (1984–87); Assistant Professor and then Professor of Law at University of Chicago Law School (1987-1995); Professor of Law at NYU Law School since 1995.
Passive Loss Rules (Portfolio 549) Gary J. Silversmith, Esq.Gary J. Silversmith, B.S., magna cum laude, University of Colorado (1977); J.D., Georgetown University Law Center, member, The Journal of Law & Policy, (1981); M.L.T., Georgetown University Law Center (1983); member: District of Columbia Bar Association, Colorado Bar Association, American Bar Association, Sections of Taxation and Real Estate; Vice President—Long & Foster Real Estate, Inc., Washington, D.C.; formerly, The Office of the General Counsel, Federal National Mortgage Association; guest lecturer at Johns Hopkins University; contributor to various legal publications.
REMICs, FASITs and Other Mortgage-Backed Securities (Portfolio 741) Horacio E. Sobol, CPAHoracio E. Sobol, B.B.A. University of Michigan, M.Acc. University of Michigan; Member AICPA; contributor to various tax journals and lecturer at various tax seminars.
S Corporations: Operations (Portfolio 731) Gary D. Sprague, Esq.Gary D. Sprague, Esq., B.A., Stanford University (1977, with honors; Phi Beta Kappa); J.D., Harvard Law School (1981, cum laude); Partner, Baker & McKenzie, LLP; Business Co-Chair of OECD Technical Advisory Group on Treaty Characterization Issues arising from E-Commerce; Business Co-Chair of OECD Technical Advisory Group on Monitoring the Application of Existing Treaty Norms for the Taxation of Business Profits; co-author, Source of Royalty Income and Place of Use of Intangible Property, Tax Management International Journal (August 2007); co-author, Permanent Establishments and Internet-Enabled Enterprises: The Physical Presence and Contract Concluding Dependent Agent Test, Georgia Law Review (Fall 2003); author, Application of Transfer Pricing Rules to Branches and Permanent Establishments—Electronic Commerce and Intangible Property Aspects, The George Mason Law Review (Summer 2002); co-author, General Report on Main Subject I: Taxation of Income Derived from Electronic Commerce, Cahiers de Droit Fiscal International (2001); co-author, United States Taxation of Income from International Electronic Commerce Transactions, Tax Management Memorandum (December 2000); co-author, The Final Software Revenue Characterization Regulations, Tax Management International Journal (February 1999); co-author, Characterization of Computer Software Revenue in International Transactions, TAXES (December 1996); member of American Bar Association; International Fiscal Association, USA Branch; State Bar of California.
Federal Taxation of Software and E-Commerce (Portfolio 555) Lisa M. Starczewski, Esq.Lisa Marie Starczewski, Smith College, B.A. (magna cum laude, 1985); Villanova University School of Law, J.D. (summa cum laude, 1988); Editor-in-Chief, Villanova Law Review (1987-88); member of adjunct faculty, Villanova University School of Law; former associate, Morgan, Lewis & Bockius; Schnader, Harrison, Segal & Lewis; author, 714 T.M., Partnerships — Allocation of Liabilities; Basis Rules; 550 T.M., At-Risk Rules; 565 T.M., Installment Sales; 621 T.M., IRS National Office Procedures — Rulings, Closing Agreements; co-author, 517 T.M., Scholarships and Educational Expenses; 5100 T.M., Revenue Recognition: Fundamental Principles (Accounting Series); 5101 T.M., Revenue Recognition: Product Sales and Services (Accounting Series); 5114 T.M., Accounting for Leases: Fundamental Principles (Accounting Series); 5117 T.M., Leases: Lessee Perspective (Accounting Series); 5118 T.M., Leases: Lessee Perspective — Selected Topics (Accounting Series); author of several chapters in the Tax Practice Series and contributor to various tax publications; recipient of Distinguished Author award; member, Tax Management U.S. Income Advisory Board.
Revenue Recognition: Fundamental Principles (Portfolio 5100)Accounting for Leases: Fundamental Principles (Portfolio 5114)Leases: Lessee Perspective (Portfolio 5117)Leases: Lessee Perspective — Selected Topics (Portfolio 5118)Leases: Lessor Perspective — Economics (Portfolio 5120)Leases: Lessors - Classification (Portfolio 5128)Revenue Recognition: Software (Portfolio 5103)Revenue Recognition: Product Sales and Service (Portfolio 5101)Scholarships and Educational Expenses (Portfolio 517)At-Risk Rules (Portfolio 550)Installment Sales (Portfolio 565)Noncorporate Alternative Minimum Tax (Portfolio 587)IRS National Office Procedures — Rulings, Closing Agreements (Portfolio 621)Partnerships — Allocation of Liabilities; Basis Rules (Portfolio 714)Corporate Alternative Minimum Tax (Portfolio 752) Samuel P. Starr, CPA Esq.Samuel P. Starr, B.S., Pennsylvania State University; J.D., University of Virginia; LL.M. in Taxation, Georgetown University Law Center; former member, AICPA, Partnership Tax Committee; former Chair, AICPA S Corporation Committee; former Co-Chair, ABA Tax Section Task Force on Taxable and Tax-Free Acquisitions Involving S Corporations; Adjunct Professor, Georgetown University Law Center; member, Board of Advisors, Journal of Business Entities; Department Editor, Journal of Taxation; speaker and lecturer, various tax institutes; author, Tax Management Portfolios 730-2nd and 731; member, State Bars of Pennsylvania and District of Columbia.
Limited Liability Companies (Portfolio 725)S Corporations: Formation and Termination (Portfolio 730)S Corporations: Operations (Portfolio 731) Ira B. Stechel, Esq.Ira B. Stechel, B.A., magna cum laude, City College of New York (1969); J.D., Cornell Law School (1972); Note Editor, Cornell International Law Journal (1971–72); LL.M. (Taxation), New York University; member, Connecticut Bar, New York Bar; American Bar Association (Section of Taxation); New York State Bar Association (Tax Section), Committee on Corporations, Committee on Partners and Partnerships; author, 519 T.M., Travel and Transportation Expenses — Deduction and Recordkeeping Requirements; contributor, Journal of Taxation, Taxation for Lawyers, Taxation for Accountants, Tax Management Real Estate Journal, Tax Ideas; lecturer, N.Y.U. Institute on Federal Taxation, Midwest Tax Institute and Fordham Law School.
Travel and Transportation Expenses — Deduction and Recordkeeping Requirements (Portfolio 519)Entertainment, Meals, Gifts and Lodging — Deduction and Recordkeeping Requirements (Portfolio 520) Christopher G. Stoneman, Esq.Christopher G. Stoneman, B.A. (law), Cambridge University (1949); LL.B., University of Virginia (1957); M.A., New York University (1989); member, New York and Vermont Bars; lecturer, Vermont Law School (1986–1995); fellow, American College of Trusts and Estates Counsel; author of several Portfolios in the estate planning field.
Deductibility of Legal and Accounting Fees, Bribes and Illegal Payments (Portfolio 523)Deductibility of Illegal Payments, Fines, and Penalties (Portfolio 524)Gross Estate — Section 2033 (Portfolio 817)Private Foundations — Excess Business Holdings (Portfolio 881) William P. StrengWilliam P. Streng, Wartburg College (B.A., 1959); Northwestern University School of Law (J.D., 1962); Law Clerk to Honorable Lester L. Cecil, Chief Judge, U.S. Court of Appeals for the Sixth Circuit, 1963-1964; associated with Taft, Stettinius & Hollister, Cincinnati, Ohio, 1964-1970; Attorney-Advisor, Office of the Assistant Secretary for Tax Policy (Office of Tax Legislative Counsel), U.S. Dept. of the Treasury, Washington, D.C., 1970-1971; Deputy General Counsel, Export-Import Bank of the United States, Washington, D.C., 1971-1973; Professor of Law, School of Law, Southern Methodist University, Dallas, Texas, 1973-1980; Visiting Professor, College of Law, The Ohio State University, 1977; Haynes & Boone, Dallas, Texas (Of Counsel, 1977-1979); Bracewell & Patterson (now Bracewell & Giuliani), Houston, Texas (partner, 1980-1985; Consultant, 1985-); Professor of Law, University of Houston Law Center (1985-); Visiting Professor, New York University School of Law (1990); Distinguished Lecturer at the University of Hong Kong Law Faculty (1992); Fulbright Professor at the University of Stockholm Law Faculty, Stockholm, Sweden (1993); Visiting Fellow at the Victoria University Law Faculty, Wellington, New Zealand (1996); Lecturer, U.S. International Taxation, University of Leiden, The Netherlands (1997 & 1998 and 2000); Visiting Professor, The University of Texas School of Law (2002); Visiting Professor, Department of International and Business Law, International Graduate School of Social Sciences, Yokohama National University, Japan (2005).
Member of American Law Institute (including its Tax Advisory Group), International Fiscal Association (including its Council), International Academy of Estate and Trust Law, American Bar Association's Section of Taxation, Tax Management Advisory Board, and various other professional organizations.
Mr. Streng is the author of the following books and portfolios: 800 T.M. Estate Planning (Tax Management, 2005), and prior versions of this Estate Planning Portfolio; Prior versions of this 700 T.M. Choice of Entity portfolio (Tax Management, 1997); “U.S. International Estate Planning” (RIAG-Warren, Gorham & Lamont, 1996), and subsequent revisions in print and on RIA Checkpoint; “International Business Transactions — Tax and Legal Handbook” (Prentice-Hall, 1978); “Estate Planning — Principles, Techniques and Materials” (Tax Management, 1981). Mr. Streng is the co-author of: Bittker, Emory & Streng, “Federal Income Taxation of Corporations and Shareholders — Forms,” 4th ed. (Warren, Gorham & Lamont, 1995, with supplements through 2005); Streng & Salacuse, “International Business Planning — Law and Taxation,” six volumes (Matthew Bender, 1982, 1985, 1986, and supplements through 2005); Streng & Davis, “Tax Planning for Retirement” (RIAG-Warren, Gorham & Lamont, revised edition 2005); Gifford & Streng, “International Tax Planning” (Tax Management, 1979); and, Streng & Wilcox, “Doing Business in China,” (Matthew Bender, 1990, and subsequent supplements).
Choice of Entity (Portfolio 700)Estate Planning (Portfolio 800)
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Alan J. Tarr, Esq.Alan J. Tarr, B.S., Brown University (1975); J.D., Vanderbilt University School of Law (1979); M.B.A., Vanderbilt University Graduate School of Management (1979); LL.M. (Taxation), New York University School of Law (1982); member, New York Bar, New York State Bar Association (Tax Section; Executive Committee (1995-2004); former co-chair, various committees); American Bar Association (Tax Section; Vice-Chair, Real Property, Probate and Trusts Committee on Federal Taxation of Real Property (2004- ); and New York City Bar Association (Tax Section; Committee on Taxation of Business Entities (2007- ); member, Tax Management Advisory Board; author, “Estimated Tax,” “Formation of a Corporation,” “Capitalization of a Corporation,” “Multiple Corporations,” and “Stapled Entities” for Tax Practice Series; co-author, 59 T.M., Corporate Liquidations: Planning and 634 T.M., Civil Tax Penalties; contributor, various journals.
Estimated Tax (Portfolio 581)Civil Tax Penalties (Portfolio 634) William Tatlock, Esq.William Tatlock, B.A., Yale University (1956); LL.B., Harvard University (1959); LL.M. (Taxation), New York University (1977); member, New York City, New York State, New Jersey, and American Bar Associations.
Discharge of Indebtedness, Bankruptcy and Insolvency (Portfolio 540) Charles B. TemkinCharles B. Temkin, Esq., B.A., Columbia University, summa cum laude (1969); J.D., Harvard University, magna cum laude (1972). Attorney advisor, U.S. Dept. of the Treasury, Office of Tax Legislative Counsel (1974-1976). Director, Deloitte Tax LLP; member, American Bar Association Section of Taxation, National Association of Real Estate Investment Trusts; D.C. Bar Taxation Section, member, Steering Committee (1989-1994), Vice-Chair and then Chair, Pass-Through Entities and Real Estate Committee (1996-2001).
Real Estate Investment Trusts (Portfolio 742) Dennis J. Tingey, J. D. CPADennis L. Tingey, B.S. Arizona State University, M.S.T., Arizona State University, J.D. Arizona State University College of Law; member American Bar Association, Tax Section; member State Bar of Arizona; member, American Institute of Certified Public Accountants.
Accounting Methods — Adoption and Changes (Portfolio 572) Steven R. Toscher, Esq.Steven R. Toscher, B.S.B.A., University of Nevada (1975); J.D., University of San Diego (1979). Trial Attorney, Tax Division, U.S. Department of Justice (1979–1983). Member: American Bar Association, State Bar of California. Principal – Hochman, Salkin and DeRoy, P.C., Beverly Hills, California.
Tax Crimes (Portfolio 636) Barry A. TovigBarry A. Tovig, B.S., magna cum laude, Montclair State University; member, AICPA – Chair, Tax Accounting Technical Resource Panel; member, D.C. Institute of CPAs; formerly with Internal Revenue Service as Tax Law Specialist, Office of Chief Counsel, Corporation Tax (1981–1986) and Internal Revenue.
Inventories: General Principles; LIFO Method (Portfolio 578) Christine M. Turgeon, CPAChristine M. Turgeon, B.B.A., Baylor University; B.S. in Taxation, American University; partner, Washington National Tax Services office of PricewaterhouseCoopers LLP; formerly of Office of Tax Legislative Counsel, U.S. Department of the Treasury (1998-2002), served as Senior Tax Law Specialist specializing in accounting methods and inventories; member, American Institute of Certified Public Accountants Technical Resource Panel on Accounting Methods.
Accounting for Long-Term Contracts (Portfolio 575)
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Marcia S. Wagner, Esq.Marcia Beth Stairman Wagner, B.A., summa cum laude, Cornell University (1984); J.D., Harvard Law School (1987), Law and Economics Fellow; Employee Benefits Committee of American Bar Association Tax Section; Tax Section Counsel, Massachusetts Bar Association; Pension Liaison Committee, IRS Key District Office, Brooklyn, New York; Massachusetts and District of Columbia Bars (1987).
ERISA — Litigation, Procedure, Preemption and Other Title I Issues (Portfolio 374)EPCRS — Plan Correction and Disqualification (Portfolio 375) James C. Warner, Esq.James C. Warner, B.A., Grove City College (1971); J.D. (cum laude; law journal editor), The Ohio State University College of Law (1974); CPA, Maryland (1979); LL.M. in Taxation (1st in class) Georgetown University Law Center (1979); Attorney-Advisor, Interpretative Division, Office of Chief Counsel, Internal Revenue Service (1974-77); Attorney-Advisor, Judge William M. Drennen, U.S. Tax Court (1978-79); Partner and Associate, Lee, Toomey, and Kent (1979-1993); Adjunct Professor, Georgetown University Law Center (1992-1994); President, USA Tax Videos (1994-1996); author, Consolidated Returns Guide (CCH, 2003); Mergers & Acquisitions Segment Leader, Ernst & Young's Online Tax Advisor (1999-2004); Senior Director, Tax Research & Planning, Wal-Mart Stores, Inc. (2004-present).
Accumulated Earnings Tax (Portfolio 796)Corporate Overview (Portfolio 750) David A. Weintraub, Esq.David A. Weintraub, B.S., Accounting, cum laude, State University of New York at Buffalo (1976); M.B.A., State University of New York at Buffalo (1977), J.D., magna cum laude, Albany Law School of Union University (1993); L.L.M. in Taxation, New York University (1994); Associate, Roberts & Holland LLP, Washington, District of Columbia; member, New York, District of Columbia, and U.S. Tax Court bars, editor, Albany Law Review, 1991-1992, co-author, articles on real estate taxation, including the Journal of Taxation and BNA publications.
Tax Court Litigation (Portfolio 630) Thomas S. Welk, Esq.Thomas S. Welk, University of Washington (B.A. 1983); Gonzaga University Law School (J.D. cum laude, 1989); New York University School of Law (LL.M., Taxation, 1990); member, California Bar; partner, Cooley Godward Kronish LLP.
Statutory Stock Options (Portfolio 381) Richard A. Westin, Esq.Richard A. Westin, B. A., Columbia University (1967); M.B.A., Columbia University (1968); J.D., University of Pennsylvania Law School; member, Kentucky Bar Association; Tax Bar Association, Court of Claims, Tax Court; Distinguished University Professor, University of Kentucky College of Law (1994-98); Foundation Professor, University of Houston Law Center (1983-84); visiting professor, University of Tennessee Law School (1979-83); Associate Professor, Chicago-Kent College of Law; former consultant to Legal Department of International Bank for Reconstruction and Development, Washington, D.C.; research fellow at University of Dundee, Petroleum and Mineral Law Centre (1992); author of 603 T.M., Mineral Properties Other Than Gas and Oil — Operation; RIA Tax Dictionary (2006-07 ed.); Taxation of International Electronic Commerce (with McNulty and Beck) (2d ed. 2007); Federal Income Taxation of Natural Resources (PLI 1994); Taxation for Environmental Protection, a Multinational Study (with Gaines, Tiley, Erikkson, Von Zezchewitz and Hertzog) (1991).
Mineral Properties — Exploration, Acquisition, Development and Disposition (Portfolio 601)Mineral Properties Other Than Gas and Oil — Operation (Portfolio 603) Gary B. Wilcox, Esq.Gary B. Wilcox, LL.M. (Taxation), New York University School of Law; J.D. (with highest honors), University of Oklahoma; B.B.A. (cum laude), Texas Tech University; former Deputy Chief Counsel, Internal Revenue Service; former Partner, PricewaterhouseCoopers, Washington National Tax Services; member, District of Columbia Bar and Pennsylvania Bar.
Corporate Acquisitions — (A), (B), and (C) Reorganizations (Portfolio 771) Donald T. Williamson, Esq.Donald T. Williamson, B.A. (Phi Beta Kappa), Hamilton College (1973); M.B.A., Johnson Graduate School of Business Administration, Cornell University (1976); J.D., Cornell Law School (1977); LL.M., Georgetown University Law Center (1983); Associate Editor, The Tax Lawyer, 1982–1983; Certified Public Accountant (Virginia, 1979); principal, LaMonaca & Williamson, CPAs, Falls Church, Virginia.
The Investment Credit and Cost Segregation (Portfolio 583) Bill C. WilsonBill C. Wilson, Partner, Executive Compensation Tax Services, Deloitte & Touche LLP; CPA; B.S., Cum Laude, University of Southern California. From June, 2002, a retired partner and a consultant to Deloitte & Touche.
Golden Parachutes (Portfolio 396) Cindy Lynn Wofford, Esq.Cindy Lynn Wofford is a principal in the law firm of Ravdin & Wofford. Ms. Wofford has practiced tax and estate planning for 20 years and domestic relations for 10 years. Prior to joining Ravdin & Wofford, Ms. Wofford was with the National Office of Chief Counsel, IRS, Tax Litigation Division, and in private practice with law firms in Dallas and Houston. A graduate of the University of Texas School of Law, Ms. Wofford received her master of laws degree in taxation from Southern Methodist University School of Law.
Divorce and Separation (Portfolio 515) Robert W. Wood, Esq.Robert W. Wood is a 1979 graduate of University of Chicago Law School where he earned a Juris Doctor and won the Florence James Adams Prize as well as a University of Chicago Scholarship. He practices law with Wood & Porter in San Francisco, California where he provides services for domestic and international clients on a variety of state, federal, and international tax matters. Mr. Wood is admitted to practice law in CA, NY, AZ, MT, WY, and DC. He is also admitted to practice as a Solicitor in England and Wales. Mr. Wood is a tax expert and has been designated by the State Bar of California as a Certified Specialist in Taxation. Mr. Wood is the author of 31 books in the field of taxation. He has long been recognized as a leading authority and commentator on several highly specialized and complex areas of the tax law. He is one of the foremost experts in the world on the taxation of damage awards and settlement payments. Mr. Wood frequently serves as a counselor and expert witness to his clients throughout the world on this unique area of the tax law and is the author of the leading treatise in the area, Taxation of Damage Awards and Settlement Payments (published by Tax Institute). Mr. Wood is also the founder and Editor-in-Chief of The M&A Tax Report, a national monthly newsletter addressing tax techniques and trends affecting mergers and acquisitions.
Tax Aspects of Settlements and Judgments (Portfolio 522)Home Office, Vacation Home, and Home Rental Deductions (Portfolio 547)Hobby Losses (Portfolio 548)Real Estate Mortgages (Portfolio 592)
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Lisa M. Zarlenga, Esq.Lisa M. Zarlenga, Esq., B.S., Ohio State University (1991); J.D., Ohio State University College of Law (1994); LL.M. (Taxation), Georgetown University Law Center (1997). Law Clerk to the Honorable Robert P. Ruwe, U.S. Tax Court, 1994-96; Partner, Steptoe & Johnson LLP, Washington, D.C.; member, American Bar Association, Tax Section — Corporate Tax Committee (Chairman of Subcommittee on Liquidations and Taxable Distributions), Government Relations Committee; 2004-2005, John S. Nolan Tax Law Fellow; District of Columbia Bar, Taxation Section — Steering Committee (member), Corporate Tax Committee (Chairman), Federal Bar Association, Tax Section; member, District of Columbia Bar and State Bar of Ohio.
Disregarded Entities (Portfolio 704)
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Howard Abrams, Esq.Howard E. Abrams, Esq., B.A., University of California at Irvine (1976; summa cum laude); J.D., Harvard Law School (1980; cum laude); Law Clerk to the Honorable Theodore Tannenwald, Jr., Chief Judge, United States Tax Court (1980-82); Professor, Emory Law School, since 1983; Adjunct Professor, University of Georgia College of Law, since 1993; Visiting Professor, Cornell Law School (1987-88); Director of Real Estate Tax Knowledge, Deloitte & Touche (1989-90); Of Counsel, Steptoe & Johnson (2003-04); co-author, Federal Income Taxation of Corporations and Shareholders (Aspen Law & Business: 3d ed. 2000); co-author, Federal Corporate Taxation (Foundation Press: 5th ed. 2002); co-author, Fundamentals of US Taxation (Kluwer Law International: 1999); member, District of Columbia Bar; member, American Law Institute; member, American Bar Association, Tax Section.
Disregarded Entities (Portfolio 704) Donald C. AlexanderDonald C. Alexander (deceased), B.A., Yale University (with honors, 1942); LL.B., Harvard University (magna cum laude, 1948). Awarded LL.D., St. Thomas Institute (1975) and Capital University (1989). Served as Commissioner of Internal Revenue (1973-1977); member of the Commission on Federal Paperwork (1975-1977), the Interior Department's Coal Leasing Commission (1983-1984), the Martin Luther King, Jr. Federal Holiday Commission (1992-1997); Chairman of the Internal Revenue Service Exempt Organizations Advisory Group (1987-1989); Harvard Law School Visiting Committee (2000-Present); Harvard Board of Overseers’ Committee on University Resources (2002-Present). Member of the American Bar Association, serving as the Vice Chairman of the Tax Section (1968-1969), the American Law Institute, and a fellow of the American College of Tax Counsel and the American College of Employee Benefits Counsel. Member of the District of Columbia, New York and Ohio Bars.
IRS Procedures: Examinations and Appeals (Portfolio 623) Peter J. Allman, Esq.Peter J. Allman, B.A., University of Maryland (1976); J.D., The Washington College of Law, The American University (1980); L.L.M., M.S.A., Georgetown University (1981, 1982); member of the District of Columbia, Connecticut, Massachusetts and New York Bars.
Withholding, Social Security and Unemployment Taxes on Compensation (Portfolio 392) Reuven S. Avi-YonahReuven S. Avi-Yonah (B.A., Hebrew University, 1983; Ph.D., Harvard University, 1986; J.D., Harvard Law School, 1989) is Assistant Professor of Law, Harvard Law School, where he teaches domestic and international taxation. Mr. Avi–Yonah is a member of the New York and Massachusetts bars and co–chairs the tax policy committee of the New York State Bar Association Tax Section. He participated in preparing the Tax Section's reports on proposed legislation on amortization of intangibles and has published several articles and comments on the leading Supreme Court case in this area, Newark Morning Ledger Co. v. United States, 113 S. Ct. 1670 (1993).
The Attribution Rules (Portfolio 554)Collapsible Corporations (Portfolio 793)Transfer Pricing: Judicial Strategy and Outcomes (Portfolio 888)
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Noah S. Baer, Esq.Noah S. Baer, B.A., Yeshiva University; J.D., Columbia University; M.L.T., Georgetown University; Executive Director, Ernst & Young, National Tax Department; Domestic and International Tax Counsel, Mobil Corporation; Senior Attorney, Office of Chief Counsel (Passthroughs and Special Industries Division), Internal Revenue Service; Senior Litigation Attorney, Office of Chief Counsel, Department of Energy; Litigation Associate, Tenzer, Greenblatt, Fallon & Kaplan, New York, NY; Member, Maryland and District of Columbia bars; Speaker at various natural resource tax conferences.
Oil and Gas Transactions (Portfolio 605) Lewis T. Barr, Esq.Lewis T. Barr, B.S., Economics, Wharton School of Finance, University of Pennsylvania (1964); J.D., University of Michigan Law School (1967); member of Ohio Bar; American College of Tax Counsel; American Law Institute; American College of Probate Counsel; contributor to various tax publications and lecturer at various tax institutes.
Net Operating Losses and Other Tax Attributes — Sections 381, 382, 383, 384, and 269 (Portfolio 780) Beth M. Benko, CPA Esq.Beth M. Benko, B.S.B.A., cum laude, Bowling Green State University (1990); J.D., Marshall-Wythe School of Law of the College of William and Mary in Virginia (1998); member, the Virginia State Bar and the District of Columbia Bar; member, the American Bar Association — Chair, Section of Taxation Tax Accounting Committee Subcommittee on Current Developments; adjunct professor, Georgetown University School of Law; certified public accountant, State of Ohio.Section 199: Deduction Relating to Income Attributable to Domestic Production Activities (Portfolio 510) Bradley T. Borden, Esq.Bradley T. Borden, B.B.A., M.B.A., Idaho State University; J.D. (Order of the Coif), LL.M. (Taxation), University of Florida Levin College of Law; Associate Professor of Law, Washburn University School of Law (courses include Taxation of Individual Income; Taxation of Partnerships and Partners; Taxation of Property Transactions; Taxation of Corporations and Shareholders; Tax Policy Seminar); Of Counsel, Oppenheimer, Blend, Harrison & Tate, Inc., San Antonio, Texas; admitted to practice, Texas, U.S. Tax Court; Certified Public Accountant; member, American Bar Association Section of Taxation (John S. Nolan Tax Law Fellow; Vice Chair, Sales, Exchanges & Basis Committee); member, Executive Committee, Kansas Bar Association Tax Law Section; author, books on §1031 (Tax-Free Like-Kind Exchanges (Civic Research Institute, 2008); Tax-Free Swaps: Using Section 1031 Like-Kind Exchanges to Preserve Investment Net Worth (DNA Press, 2007)); author, various articles in leading tax journals (including Journal of Taxation; Real Estate Taxation; Tax Management Memorandum; Tax Management Real Estate Journal; Tax Notes; Taxes: The Tax Magazine) and several law reviews (including Florida Law Review; Houston Law Review; Kansas Law Review; South Carolina Law Review; Virginia Tax Review); frequent speaker, tax law topics.
Real Estate Transactions by Tax-Exempt Entities (Portfolio 480)Real Estate Transactions by Tax-Exempt Entities (Portfolio 591) Janine H. Bosley, Esq.Janine H. Bosley, University of Miami (B.S.B.A. 1981, M.P.A. 1982, J.D. 1986); formerly, Senior Attorney, Office of Associate Chief Counsel (Employee Benefits and Exempt Organizations), Internal Revenue Service; Member of the Virginia, United States Tax Court, and United States Supreme Court Bars; Liaison Member of the IRS Employee Benefits Conference Committee, Southeast Region; Vice Chair of the American Bar Association, Tort and Insurance Practice Section, Committee on Employee Benefits; and Member of the American Bar Association Section of Taxation, Committee on Employee Benefits.
Employee Benefits for Small and Mid-Sized Employers (Portfolio 353)Qualified Plans — Taxation of Distributions (Portfolio 370) Lawrence Brody, Esq.
Lawrence Brody, partner, Bryan Cave LLP; B.S., University of Pennsylvania (Wharton) (1964); J.D., Washington University School of Law (1967); LL.M. in Taxation, New York University School of Law (1968); Partner, Bryan Cave LLP, an international law firm, resident in the St. Louis office, and member of its Private Client Service Group and its Technology, Entrepreneurial & Commercial Practice Client Service Group; adjunct professor, Washington University School of Law, teaching Estate Planning and Drafting; visiting adjunct professor, the University of Miami Law School, teaching a course on Life Insurance; author or co-author, numerous articles and books on the use of life insurance in estate and employee benefit planning, including two BNA Tax Management Portfolios, two books for the National Underwriter Company, and a number of volumes in the ABA Insurance Counselor Series; fellow, American College of Trust and Estate Counsel (ACTEC) and American College of Tax Counsel; frequent participant, ALI-ABA programs and Society of Financial Professionals programs and teleconferences; speaker, all major life insurance industry programs (including the MDRT, the Top of the Table, AALU and the International Forum), many local estate planning council meetings, a number of state bar association conferences, and many national estate planning programs; member, Advisory Committee for the Philip E. Heckerling Institute on Estate Planning of the University of Miami School of Law; member, Editorial Boards of BNA Tax Management's Estates, Gifts, and Trusts Journal, and the Society of Financial Service Professionals CLU Journal; designated, Accredited Estate Planner by the National Association of Estate Planners and Councils, and one of 10 individuals awarded its Distinguished Accredited Estate Planner designation in the initial class, in 2004.
Compensating Employees with Insurance (Portfolio 386)Section 2035 Transfers (Portfolio 818)Compensating Employees with Insurance (Portfolio 828) Gregory K. Brown, Esq.Gregory K. Brown, University of Kentucky (B.S. 1973), University of Illinois (J.D. 1975); member, Illinois Bar. Past Chairman, member, Legislative and Regulatory Advisory Committee, The ESOP Association. Past Member, Board of Directors, The ESOP Association. Past Chairman, Chicago Bar Association, Employee Benefits Committee. Member, ABA Tax Section, Employee Benefits Committee.
ESOPs (Portfolio 354) Karen B. BrownKaren B. Brown, B.A., Princeton University; J.D., LL.M., New York University, the Donald Phillip Rothschild Research Professor of Law at the George Washington University School of Law, where she teaches courses in Federal Income Taxation, Corporate Taxation, and International Taxation. Before joining the faculty at George Washington University, Professor Brown was Professor of Law and Associate Dean for Academic Affairs at the University of Minnesota Law School and Professor of Law at Brooklyn Law School. She has published numerous articles concerning corporate and international taxation. Professor Brown is co-author of an international tax transactions treatise and co-editor of a book on taxation reform. She is a member of the International Fiscal Association.
The Attribution Rules (Portfolio 554)Innocent Spouse Relief (Portfolio 645)
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Oguz Caginalp, Esq.Oggie Caginalp, B.A., Tufts University; M.B.A. New York University Graduate School of Business; J.D., Boston College Law School; LL.M (in Taxation), New York University School of Law; Attorney, Tax Department, Brown & Wood; Attorney, Tax Department, Rogers & Wells; Vice President and Senior Tax Counsel, Corporate Tax Division, Citibank, N.A; Vice President, Capital Structuring Group, Citibank, N.A, Senior Vice President and Head of Tax, Commerzbank Capital Markets Corporation (2000-present).
The Mark-To-Market Rules of Section 475 (Portfolio 543) Michael Carnevale, CPA Esq.Michael K. Carnevale, Esq., University of Michigan (1982); University of Detroit (1990). Certified Public Accountant (New York, New Jersey, Michigan); Partner, Deloitte Tax LLP; member, American Institute of Certified Public Accountants, Michigan Society of Certified Public Accountants, American Bar Association, Michigan Bar Association, and National Association of Real Estate Investment Trusts.
Real Estate Investment Trusts (Portfolio 742) James E. Carreon, Esq.James E. Carreon, J.D., Southwestern University School of Law; B.S. and B.A., University of Southern California; State Bar of California; Adjunct Professor, Golden Gate University, Master of Tax Program.
Related Party Transactions (Portfolio 564) Elizabeth A. Case, Esq.Elizabeth A. Case, B.A., Millsaps College; M.B.A., Southern Methodist University; formerly Special Assistant to the Deputy Chief Counsel, Internal Revenue Service; Participant, AICPA Partnership Taxation Technical Resource Panel.
Limited Liability Companies (Portfolio 725) R. Lee Christie, Esq.Lee Christie is a partner in the Chicago office of Hopkins & Sutter whose practice focuses on tax matters for insurance industry clients, including property and casualty insurers, life and health insurers, HMOs, Blue Cross organizations, insurance trade associations, and insurance guaranty associations. He graduated from Illinois Wesleyan University in 1981 and Harvard Law School in 1984. Lee has served as Chair of the Subcommittee on Life Insurance Companies of the ABA Tax Section Committee on Insurance Companies.
Annuities, Life Insurance, and Long-Term Care Insurance Products (Portfolio 546) James T. Chudy, Esq.James T. Chudy, B.S. with Honors, Phi Beta Kappa, University of Wisconsin–Madison (1981); J.D., Harvard Law School (1984); Executive Editor, Harvard Civil Rights-Civil Liberties Law Review; The Association of the Bar of the City of New York (Council on Taxation, Secretary, 1990–1993).
Stock Purchases Treated as Asset Acquisitions — Section 338 (Portfolio 788) Bruce A. Cohen, Esq.Bruce A. Cohen, B.A., Case Western Reserve University (1984) (Phi Beta Kappa, summa cum laude); J.D., Columbia University (1987); Associate International Tax Counsel and Attorney Advisor, Office of Internal Tax Counsel, Department of the Treasury, 1995-1997; Partner, Baker & McKenzie LLP, 2001-2007; Harlan Fiske Stone Scholar; member, Internal Fiscal Association; member, State Bar of California, District of Columbia Bar, Illinois State Bar Association, Tax Court Bar, American Bar Association Section on Taxation.
Federal Taxation of Software and E-Commerce (Portfolio 555)Research and Development Expenditures (Portfolio 556) Toby Cozart, Esq.Toby Cozart, B.A., University of North Carolina (1974); J.D., Duke University (1978); M.S. in Philosophy, University of North Carolina (1979); LL.M. in Taxation, New York University School of Law (1981). Law office, Piedmont, California. Previously: Tax Counsel, GATX Capital Corporation, San Francisco, California; Partner, Lillick, McHose & Charles, San Francisco, California; Associate, Morgan, Lewis & Bockius, New York, New York; Staff Counsel, Subcommittee on Oversight, Committee on Ways and Means, U.S. House of Representatives, Washington, D.C.; Member of the Bars of the District of Columbia, New York, California, and the United States Tax Court.
Equipment Lease Characterization (Portfolio 545)Equipment Leasing: Substance and Form (Portfolio 544) Robert J. Crnkovich, Esq.Robert J. Crnkovich, B.S., J.D., Marquette University; LL.M. in Taxation, Georgetown University Law Center; Adjunct Professor, Georgetown University Law Center; member, State Bars of Wisconsin, California, and District of Columbia.
Limited Liability Companies (Portfolio 725) Frank Cummings, Esq.Frank Cummings, B.A. with high honors, Hobart College (1951), Phi Beta Kappa; M.A., Columbia University (1955); L.L.B., Columbia University School of Law (1958), Harlan Fiske Stone Scholar; Articles Editor, Columbia Law Review; Chairman, ALI-ABA Annual Course in Employee Benefits Litigation; Co-Chairman, ALI-ABA Annual Course in Employment & Labor Relations Law for the Corporate Counsel & General Practitioner; member, The American Law Institute, American Bar Association; former Chairman, District of Columbia Bar Association (Labor Committee); Association of the Bar of the City of New York, District of Columbia Bar and the State Bar of New York; Lecturer in Law, University of Virginia Law School; former member, U.S. Department of Labor Advisory Council on Employee Welfare and Pension Benefit Plans.
Pension Plan Terminations — Single Employer Plans (Portfolio 357)
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James P. DeBree, Jr. CPAJames P. de Bree, Jr., B.S., California State University Northridge (1975). Certified Public Accountant (California); Partner, Deloitte Tax LLP; member, American Institute of Certified Public Accountants, California Society of Certified Public Accountants, National Association of Real Estate Investment Trusts; author of numerous articles on REITs and REIT taxation; frequent speaker on REIT-related matters.
Real Estate Investment Trusts (Portfolio 742) Louis H. Diamond, Esq.Louis H. Diamond, Esq.; LL.M. in Taxation, Georgetown University Law Center; J.D., Cum Laude, George Washington University National Law Center; B.A., George Washington University; Managing Member of Diamond ESOP Advisors PLLC, is one of the leading ESOP (Employee Stock Ownership Plan) attorneys in the country. Mr. Diamond is a past chairman of the ESOP Association’s Legislative and Regulatory Advisory Committee. He previously served as attorney advisor at the United States Tax Court, is a Charter Fellow of the American College of Employee Benefits Counsel and a Fellow of the American College of Tax Counsel. His work with ESOPs is all encompassing, ranging from representing owners selling stock to an ESOP, employees pooling ESOP funds to purchase their division/subsidiary from corporations large and small, banks and others making ESOP loans and ESOPs themselves and their trustees. Representing the employees of the Illinois Institute of Technology Research Institute (now Alion Science and Technology) in a $130 million employee buyout of its operating assets is among Mr. Diamond’s most notable ESOP achievements.
Accounting Methods — General Principles (Portfolio 570) Beth J. Dickstein, Esq.Beth J. Dickstein, B.S., University of Illinois (1985, with highest honors); J.D., University of Pennsylvania Law School (1988, cum laude); Certified Public Accountant; member of the Tax Section of the American Bar Association.
Qualified Plans — Investments (Portfolio 377) Glenn W. Dowd, Esq.Glenn W. Dowd, Central Connecticut State University (B.A. cum laude, 1984), University of Connecticut School of Law (J.D. high honors, 1989); member, Connecticut Bar; associate, Day, Berry & Howard.
Reductions Force (Portfolio 398) David S. Dunkle, Esq.David S. Dunkle, B.A., Virginia Military Institute (Honors in English 1966); J.D., University of North Carolina Law School (member of Law Review 1969); LL.M. (Taxation) Georgetown Law Center (1970); member Alabama State Bar, North Carolina State Bar, American Bar Association (Section of Taxation); contributor to The Journal of Taxation, TAXES, Law Office Economics and Management, The North Carolina Bar Association BAR NOTES, and The North Carolina Law Review; author of treatise: Guide to Pension and Profit Sharing Plans, Shepard's/McGraw–Hill, 1984.
VEBAs and Other Self-Insured Arrangements (Portfolio 395)
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Bruce N. Edwards, Esq.Bruce N. Edwards, B.A., The Colorado College; J.D., University of Washington School of Law; LL.M. (in Taxation), New York University; former Law Clerk to the Honorable Shiro Kashiwa, Associate Judge, the United States Court of Claims (now the Court of Appeals for the Federal Circuit); former New Decisions Editor, The Journal of Taxation; selected as Super Lawyer, Washington Law & Politics (2005, 2004, 2003); author, “Understanding and Making the New Section 646 Election for Alaska Native Settlement Trusts,” 18 Alaska Law Review 219 (Duke University 2001); “Understanding and Using ‘Partnership Redemptions' in the Context of Section 1(h),” 45 Tax Mgmt. Memo. No. 19, 1 (Sept. 20, 2004); 568-3rd T.M., Involuntary Conversions; 594-2nd T.M., Tax Implications of Home Ownership; Tax Practice Series: Chapter 1510, Tax Free Exchanges; Chapter 1520, Involuntary Conversions; Chapter 2650, Taxation of Timber; Chapter 3880, Tax Court Litigation; Chapter 3890, Refund Litigation; Chapter 3850, IRS Audit Procedures; Chapter 3860, Statute of Limitations; member, Washington and Alaska Bars; member, American Bar Association (Section of Taxation, Committee on Court Procedure); member, American College of Tax Counsel.
Involuntary Conversions (Portfolio 568)Tax Implications of Home Ownership (Portfolio 594)Timber Transactions (Portfolio 610) William E. Elwood, Esq.William E. Elwood, B.S., Pennsylvania State University (1965); J.D., University of Pennsylvania Law School (1968); LL.M. (Taxation), Georgetown University (1975); also attended Universität zu Köln Cologne, Germany (1963) and the Hague Academy of International Law (1967); formerly Technical Attorney, Tax Court Litigation Division, Office of Chief Counsel, Internal Revenue Service (1970-1974); and associated with Lee, Toomey & Kent, attorneys, Washington, D.C. (1974-1977); Tax Counsel and subsequently Assistant General Counsel, Communications Satellite Corporation, Washington, D.C. (1977-1985); Vice President and Tax Counsel, Primark Corporation, McLean, Virginia (1985-1987); Served as National Federal Tax Chairman, Tax Executives Institute (1984-1985); Corporation Department Editor, The Tax Times (1984-1987); Articles Editor, The Tax Lawyer (1976-1980); member of the District of Columbia, Michigan and Pennsylvania Bars; American Bar Association, Section of Taxation, and Metropolitan Detroit Bar Association.
Employee Fringe Benefits (Portfolio 394)
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Charles E. Falk, Esq.Charles Edward Falk, B.A. (in economics), University of Kansas (1970); M.S. (in accounting), The University of Virginia (1976); J.D., Washington and Lee School of Law (1979); LL.M. (in taxation), New York University School of Law (1981); LL.M. in Corporation Law (Bankruptcy and Securities Laws), New York University School of Law (1991); Principal, Mortenson and Associates, Cranford, N.J.; member, New Jersey and Virginia Bars; Certified Public Accountant, New Jersey and Virginia; author, Tax Management Portfolio, Tax Planning for the Development and Licensing of Patents and Know–How, No. 557.
Tax Planning for the Development and Licensing of Patents and Know-How (Portfolio 557)Tax Planning for the Development and Licensing of Copyrights, Computer Software, Trademarks and Franchises (Portfolio 558) Felicia A. Finston, Esq.Felicia A. Finston, Arizona State University (B.S. in Personnel Management, magna cum laude, 1982); University of Utah (M.S. in Human Resource Management, with honors, 1983); University of New Mexico School of Law (J.D., with honors, 1986); member, State Bar of Texas, Dallas Bar Association, State Bar of Arizona, Maricopa County Bar Association, American Bar Association, and SouthWest Benefits Association.
Plan Qualification — Pension and Profit-Sharing Plans (Portfolio 351) James W. Forsyth, Esq.James W. Forsyth, B.S. (summa cum laude), West Liberty State College (1983); J.D. (Order of the Coif), West Virginia University College of Law (1986); LL.M. (Taxation), University of Florida College of Law (1989); admitted to practice in Pennsylvania and West Virginia; member, American Bar Association, Section of Taxation, Committee on Partnerships; member, Allegheny County and Pennsylvania Bar Associations; member, West Virginia Bar Association; certified public accountant (1988); member, American Institute of Certified Public Accountants; member, West Virginia Society of Certified Public Accountants; adjunct lecturer, West Virginia University College of Law (1993-2001).
Stock Rights and Stock Dividends — Sections 305 and 306 (Portfolio 765) Anjanette T. Frias, Esq.Anjanette T. Frias, B.A. (cum laude), Creighton University (1993); J.D., Emory University School of Law (1996); member, Tennessee Bar Association (1996-2002); co-author, “Consolidated Return Election Offers Tax Advantages—With Complexity,” Tax Strategies (Sept. 2001); Ernst & Young, LLP (1996-2001); Responder, Mergers & Acquisitions Segment, Ernst & Young's Online Tax Advisor (2001-2003).
Corporate Overview (Portfolio 750)Dividends — Cash and Property (Portfolio 764) Richard C. Fung, Esq.Richard C. Fung, Amherst College (B.A., cum laude, 1991); Columbia University School of Law (J.D. 1994); Associate, Skadden, Arps, Slate, Meagher & Flom LLP (1994-2001); Senior Manager, Ernst & Young LLP, National Office West, Mergers & Acquisitions; contributing author, Practising Law Institute: Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings (2001).
Personal Holding Companies (Portfolio 797)
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William Galanis, Esq.William Galanis, LL.M., in Taxation, (with distinction), from Georgetown University; J.D. from the Columbia School of Law, Catholic University; B.S. in Accounting, (cum laude) from Mt. St. Mary's College. Member of the District of Columbia and Maryland State bar associations. Formerly Attorney/Advisor, Office of Chief Counsel, Internal Revenue Service.
Earnings and Profits (Portfolio 762) John A. Galotto, Esq.John A. Galotto, B.A., Johns Hopkins University (1988); J.D., Columbia Law School (1993); Senior Editor, Columbia Law Review; Trial Attorney, U.S. Department of Justice, Tax Division, Civil Trial and Criminal Enforcement Sections, 1995-2000; Special Assistant U.S. Attorney, District of Columbia, 1999; Law Clerk to U.S. District Court Judge Edward Rafeedie, Central District of California, 1993-1994; co-author: “Right To Counsel: Courts Adhere to Bright-Line Limits,” ABA Criminal Justice Magazine, Summer, 2001 at 4; co-author, “Sensible Decision on Admissibility of Witness Guilty Pleas Repudiated in Third Circuit, but Dissenters Offer Hope in Other Circuits,” White Collar Crime Reporter, June/July 2000, at 1; co-author, “The COSO Report on Internal Control: Implications for Public Companies and Executives,” Insights, August 1993, at 29; member, American Bar Association, Section of Taxation, Committee on Court Procedure; member, bars of the District of Columbia, New York and Illinois.
Obtaining Information from the Government — Disclosure Statutes (Portfolio 625) Nancy J. Glover, CPA Esq.Nancy J. Glover, B.S., magna cum laude, University of Utah (1985); M.S.T., DePaul University (1992); J.D., Chicago-Kent College of Law (1998); member, American Institute of Certified Public Accountants and the Illinois Institute of Certified Public Accountants; frequent guest speaker, Tax Executives Institute, Inc. (TEI), FSC/DISC Tax Association, Inc. (FDTA), and Council for International Tax Education (CITE).
Section 199: Deduction Relating to Income Attributable to Domestic Production Activities (Portfolio 510) Carlos Gonzalez-Padro, Esq.Carlos Gonzalez-Padro, B.B.A. with a major in accounting, University of Puerto Rico (1991); J.D., University of Puerto Rico (1994); LLM in Taxation with an Employee Benefits Certificate, Georgetown University Law Center (2001). Certified Public Accountant; Member, Georgia, Puerto Rico, and Washington, DC Bar Associations; Member of the American Bar Association Section of Taxation; advisor to the U.S. Treasury Department and the IRS on Puerto Rico plan initiatives; frequent lecturer and author of various articles on employee benefits in Puerto Rico.
International Pension Planning — Puerto Rico (Portfolio 324) Luis Granados, Esq.Luis Granados, Brown University (A.B. 1975), Georgetown University Law Center (J.D. 1978); member, District of Columbia and Maryland Bars. Past Chairman, Legislative and Regulatory Advisory Committee, The ESOP Association.
ESOPs (Portfolio 354)
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Russell E. HallRussell E. Hall, J.D., Fordham Law School (1978), LL.M. in taxation, New York University School of Law (1979), B.A., S.U.N.Y. at Albany (1975); member, New York State Bar; member, Retirement Security Committee, ERISA Industry Committee; member, Tax Law Section, American Bar Association; member, International Pension and Employee Benefit Lawyers Association (IPEBLA).
International Pension Planning (Portfolio 320) R. Arnold Handler, Esq.R. Arnold Handler, B.A., University of Rochester (undergraduate study also at London School of Economics); J.D., Harvard Law School; LL.M (in Taxation), New York University School of Law; Captain, Judge Advocate Generals Corps, U.S. Army; Attorney, Tax Department, Carter, Ledyard & Milburn; Senior Tax Attorney, Mobil Corporation; Senior International Tax Counsel, Citigroup (1990-present).
The Mark-To-Market Rules of Section 475 (Portfolio 543) Richard M. Hervey, Esq.Richard M. Hervey, Dechert LLP, New York, NY; B.A., Herbert Lehman College (1972); M.A., University of California, Berkeley (1975); J.D., Harvard Law School (1978); admitted, New York Bar; member, American Bar Association (Section of Taxation); Committee on Regulated Investment Companies, New York State Bar Association (Section on Taxation).
Taxation of Regulated Investment Companies (Portfolio 740) Barry Herzog, Esq.Barry Herzog, B.A., Yeshiva University (1987); J.D., Columbia University (1991); member, New York State Bar Association, Committee on Corporations; member, American Bar Association, Section of Taxation; member, New York State Bar; co-author, Tax Management Portfolio No. 561, Capital Assets.
Capital Assets (Portfolio 561)Transfers to Controlled Corporations: General (Portfolio 758)Transfers to Controlled Corporations: Related Problems (Portfolio 759) David A. Hildebrandt, Esq.David A. Hildebrandt, B.S., Brigham Young University (1967); J.D., Order of the Coif, University of Wisconsin (1970); note and comment editor, Wisconsin Law Review (1970); member, American Bar Association Section of Taxation, District of Columbia Bar, State Bar of Wisconsin, U.S. Supreme Court; Certified Public Accountant, Wisconsin (1974).
Qualified Plans — IRS Determination Letter Procedures (Portfolio 360)Qualified Plans — Treatment Mergers, Acquisitions and Other Corporate Transactions (Portfolio 364) Bruce I. Hochman, Esq.Bruce I. Hochman, B.A., University of Toronto and University of California at Los Angeles (1949); J.D., University of California at Los Angeles (1952); Graduate Certificate in Taxation, University of Southern California (1957). Assistant U.S. Attorney, Southern District of California, Tax Division (1953–1956). Hearing Officer, Department of Justice (195801968). Member: American Bar Association, State Bar of California. Fellow, American College of Trial Lawyers. Certified specialist, Criminal and Taxation Law, California Board of Legal Specialization. Principal – Hochman, Salkin and DeRoy, P.C., Beverly Hills, California, a firm specializing in federal and state taxation, corporation law and civil, criminal and tax litigation.
Tax Crimes (Portfolio 636) Philip J. Holthouse, Esq.Philip J. Holthouse, B.S., University of Southern California (summa cum laude, 1981); M.B.T., University of Southern California (1986); J.D., Loyola Law School — Los Angeles (Order of the Coif, 1993); adjunct professor, University of Southern California Master of Business Taxation Program (1988 – ); author of numerous articles on federal taxation; member of the American Bar Association, State Bar of California, American Institute of Certified Public Accountants, California Society of CPAs; Partner — Holthouse Carlin & Van Trigt LLP (CPAs); Partner — Sherry, Coleman & Holthouse LLP (Attorneys at Law).
Real Estate Leases (Portfolio 593) Edward B. Horahan IIIEd Horahan currently acts as of counsel to the Groom Law Group, Chartered, in Washington, D.C. A 1976 graduate of Yale Law School, he formerly served on the staff of the Securities and Exchange Commission and litigated ERISA cases while with the Solicitor's Office of the Department of Labor. In the private sector, he was a partner in the Washington offices of New York City law firms and the proprietor of his own law practice.
ERISA — Fiduciary Responsibility and Prohibited Transactions (Portfolio 365) Helen M. Hubbard, Esq.Helen M. Hubbard, Esq., B.B.A., Texas Tech University (1975); J.D., Southern Methodist University School of Law (1987, magna cum laude); Law Clerk to the Honorable Irving L. Goldberg, U.S. Court of Appeals for the Fifth Circuit (1987-88); Tax Legislative Counsel, United States Department of the Treasury (2002-05); Partner, Baker & McKenzie LLP; member, State Bar of Texas, District of Columbia Bar, American Bar Association Section of Taxation (Council, 2006-present; Chair, Simplification Committee, 2007-present; Assistant Secretary, 2004-05; Chair, Tax Accounting Committee, 1996-98); Adjunct Professor of Law at Southern Methodist University Dedman School of Law (2006) and Georgetown University Law Center (1996-2001); Fellow, American College of Tax Counsel; Certified Public Accountant.
Federal Taxation of Software and E-Commerce (Portfolio 555)
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Kathy Davidson Ireland, Esq.Kathy Davidson Ireland, B.S., Lebanon Valley College (1977); J.D., Order of the Coif, Marshall-Wythe School of Law, College of William & Mary; Executive Editor for Student Contributions, William & Mary Law Review (1980), LL.M., Labor Law, The National Law Center, George Washington University (1982); member: District of Columbia Bar, Maryland Bar.
Qualified Plans — IRS Determination Letter Procedures (Portfolio 360)
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Carl M. Jenks, Esq.Carl M. Jenks, J. D. Harvard Law School (1980); Ph.D. Duke University (1979), M.A. Duke University (1973); B.A. Carleton College (1967).
Corporate Bankruptcy (Portfolio 790)
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Jared Kaplan, Esq.Jared Kaplan, University of California at Los Angeles (A.B. 1960), Harvard University (LL.B. 1963); member, Illinois Bar. Past Chairman, Legislative and Regulatory Advisory Committee, The ESOP Association.
ESOPs (Portfolio 354) Yoram Keinan, Esq.Yoram Keinan, B.A., LL.B., Tel Aviv University; LL.M. (Taxation), Hebrew University; M.B.A., Bar Ilan University; M.P.A., LL.M. (International Taxation), Harvard University; LL.M. (Taxation), J.S.D., University of Michigan. As Counsel with Greenberg Traurig, Mr. Keinan specializes in United States taxation of financial products and institutions and represents major investment banks and financial institutions in the United States. Prior to joining Greenberg Traurig, Mr. Keinan was with Ernst & Young's National Tax Department in Washington, D.C. Before that, Mr. Keinan practiced with Shearman & Sterling and with Ernst & Young's tax department in Israel. He has authored numerous articles and has taught Harvard's International Tax Program, Kennedy School of Government, and School of Arts and Sciences (Department of Economics).
Accounting for Debt Instruments (Liabilities) (Portfolio 5105)The Economic Substance Doctrine (Portfolio 508) David I. Kempler, Esq.David I. Kempler, J.D., 1966, University of Connecticut; LL.M., 1967, The George Washington University Law School, taxation; B.S., 1963
University of Pennsylvania. Mr. Kempler is admitted to Connecticut, District of Columbia and the United States Supreme Court. He focuses his practice on corporate tax, business planning and not-for-profit (especially in the health care area) tax matters. He advises clients on a broad range of tax issues involving mergers and acquisitions, closely held entities, joint ventures and planning for health care entities. David is editor of the Corporate Tax and Business Planning Review and has written many articles in the tax area. He is a frequent speaker at tax conferences and is a member of the Corporate Relationships and Exempt Organizations Committee of the American Bar Association Section of Taxation. In 2006, he was selected by his peers for inclusion in The Best Lawyers in America. He is affiliated with the District of Columbia Bar, Federal Bar Association and the American Bar Association.
Boot Distributions and Assumption of Liabilities (Portfolio 782) Kathryn J. KennedyKathryn J. Kennedy; Drake University (B.S., with honors, 1974); Fellow of the Society of Actuaries (F.S.A., 1976); Northwestern University School of Law (summa cum laude, Order of the Coif, Article Editor for the Northwestern University Law Review, 1980); Professor of Law and Director of the Center for Tax Law and Employee Benefits, John Marshall Law School; member of the ABA Section of Taxation; former chair of the ISBA Employee Benefits Section Council; chair of the CBA Employee Benefits Committee.
IRAs (Portfolio 367)SEPs and SIMPLEs (Portfolio 368) Barbara L. Kirschten, Esq.Barbara L. Kirschten, B.A., University of Pennsylvania (summa cum laude); Honours B.A., Cambridge University; Ph.D., M.A., Harvard University; J.D., Northwestern University; member, New York and District of Columbia Bars; former member, Steering Committee District of Columbia Bar Association Taxation Section and former Chair, Exempt Organizations Committee; Co-Chair, Subcommittee on Museums of Other Cultural Organizations, Exempt Organizations Committee, ABA Section of Taxation; author, The Nonprofit Corporation Forms Handbook; co-author, Federal and State Taxation of Exempt Organizations.
Charitable Contributions: Income Tax Aspects (Portfolio 521)Charitable Contributions: Income Tax Aspects (Portfolio 863) James P. Klein, Esq.James P. Klein, J.D., Columbia University Law School (1972), LL.M. in taxation, New York University Law School (1979), B.A., Fordham University (1968); member, New York State Bar; member, past chair, Employee Benefits Committee, Section of Taxation, American Bar Association; member, past chair, Employee Benefits Committee, Tort and Insurance Section, American Bar Association; member, Tax Management Advisory Board; founding member and past chair, International Pension and Employee Benefits Lawyers Association (IPEBLA).
International Pension Planning (Portfolio 320) Michael J. Kliegman, Esq.Michael J. Kliegman, A.B., University of Pennsylvania; J.D., Boston University School of Law, LL.M. (Taxation), Georgetown University Law Center; member: American Bar Association, Tax Section (Corporate Tax Committee; Task Force on Acquisitions Involving S Corporations); New York State Bar Association, Tax Section (Committee on Reorganizations); formerly, Internal Revenue Service, Office of Chief Counsel, Reorganization Branch (1981–85), Group Chief (1984–85).
Single Entity Reorganizations: Recapitalizations and F Reorganizations (Portfolio 774) Steven E. KligSteven E. Klig, B.A. (cum laude), C.U.N.Y., Queens College; J.D. (cum laude), Fordham University School of Law; LL.M. (Taxation), New York University School of Law; member, American Bar Association and the New York State Bar Association and their respective Tax Sections; admitted to practice in New York, Colorado, Connecticut, and the District of Columbia; speaker, various conferences including the American Bar Association and the Bank Tax Institute; author, various articles in NYU Institute of Taxation, Tax Management Memorandum, and Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures, & Other Strategic Alliances (Practising Law Institute).
Partnerships — Taxable Income; Allocation of Distributive Shares; Capital Accounts (Portfolio 712) George C. Koutouras, Esq.George C. Koutouras, LL.M. (Taxation), Georgetown University Law Center; J.D., University of Detroit School of Law; B.S.A., University of Michigan; bar membership, Michigan and Illinois; formerly Attorney/Advisor to Special Trial Judge Stanley J. Goldberg, United States Tax Court; Co-Author, 767-2nd T.M., Redemptions and 564 T.M., Related Party Transactions; Adjunct Professor, University of Illinois Urbana-Champaign Master of Tax Program.
Related Party Transactions (Portfolio 564)Redemptions (Portfolio 767)Stock Sales Subject to Section 304 (Portfolio 768)Boot Distributions and Assumption of Liabilities (Portfolio 782) Michael G. Kushner, Esq.Michael G. Kushner, B.A., George Washington University (1974); J.D., University of Virginia School of Law (1977); LL.M. (Taxation), George Washington University (1982). Co-author, The Employee Benefits Desk Encyclopedia (BNA Books, 1995); Retirement & Welfare Benefit Plans (BNA Books, 1989); co-editor, ERISA, The Law and the Code (BNA Books); co-editor, ERISA Regulations (BNA Books). Member, District of Columbia, Maryland and Virginia Bars. Adjunct faculty member, Georgetown University Certified Employee Benefits Specialist Program (1982-88); adjunct faculty member, The Dickinson College School of Law (1989-91).
Multiemployer Plans — Special Rules (Portfolio 359)Reporting and Disclosure Under ERISA (Portfolio 361)
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Howard J. Levine, Esq.Howard J. Levine, B.A., Hunter College (1969); J.D., State University of New York at Buffalo (cum laude, 1972); LL.M. (Taxation), Georgetown University Law Center (1976); attorney and assistant branch chief, Office of Chief Counsel, Internal Revenue Service (1972-1976); adjunct lecturer in Real Estate Taxation, American University Law School (1980-1982); adjunct professor, The George Washington University Law School and Georgetown University Law Center LL.M. Tax Programs (1982-1993); contributing editor, The Journal of Real Estate Taxation; Tax Management Distinguished Author (2000); member, Advisory Board, Tax Management International Journal; member, Advisory Board, CCH Journal of Taxation of Global Transactions; author, 936 T.M., U.S. Income Tax Treaties — The Limitation on Benefits Article; partner, Roberts & Holland LLP, Washington, D.C. and New York, N.Y.; member, American Bar Association (Chairman, Committee on Sales, Exchanges and Basis, and Subcommittee Chairman, Like Kind Exchanges, Tax Section 1990-1994), New York Bar, District of Columbia Bar, International Fiscal Association.
U.S. Income Tax Treaties — The Limitation on Benefits Article (Portfolio 936) Richard A. Levine, Esq.Richard A. Levine, B.S., Economics, University of Pennsylvania (1964); J.D., Harvard Law School (1967); L.L.M., New York University (1968); member, New York, U.S. Tax Court, Court of Federal Claims, U.S. Supreme Court, U.S. Court of Appeals (Second Circuit), U.S. District Court, and Southern and Eastern Districts of New York Bars; editor, Harvard Law Review, 1965-1967; editor-in-chief, Roberts & Holland, Annotated Tax Forms — Practice and Procedure (3d ed.); co-author, “Tax Court's Revised and Expanded Partnership Rules Leave Questions Open,” 69 Journal of Taxation 164 (Sept. 1988); member, The Association of the Bar of the City of New York, New York State and American Bar Associations (Sections on Taxation; Litigation); contributor, Journal of Taxation and other tax periodicals.
Tax Court Litigation (Portfolio 630) Jack B. Levy, Esq.Jack B. Levy, Partner, Balch and Bingham LLP, Birmingham, AL; New York University School of Law, LL.M., in Taxation, 1977; Emory Law School, J.D., 1976; Emory University, B.A., 1973. He is admitted to Alabama and Georgia. Mr. Levy concentrates his practice in the areas of employer resources, employee benefits and executive compensation, corporate and business, health care, taxation and estate and trust planning. He represents numerous closely held businesses, professionals and professional corporations and negotiates and closes sales of professional practices and closely held business practices. He also lectures on issues relating to pension and welfare benefits as well as health care matters. He is listed in The Best Lawyers in America, 1995 Edition - Present (Employee Benefits Law); 2007 Edition (Corporate Law); 2008 Edition (Healthcare Law), and is a member of the American Health Lawyers Association; Southern Employee Benefit Conference; American Bar Association, Tax Section; Alabama State Bar, Tax Section; Alabama Profit Sharing Council; Alabama Super Lawyers, 2009.
Employee Benefits for Small and Mid-Sized Employers (Portfolio 353) Henry J. Lischer, Jr.Henry J. Lischer, Jr., University of Iowa (B.B.A., 1967; J.D., 1970); New York University (LL.M. in Taxation, 1974); Judge Advocate, U.S. Marine Corps, 1970–73; Associate, Lillick, McHose & Charles, Los Angeles, California, 1974–75; Professor of Law, University of Alabama, 1975–78; Professor of Law, Southern Methodist University, 1978–present; Counsel, Malouf Lynch Jackson & Swinson, Dallas, Texas, 1982–84, 1985–present; Professor-in-Residence, Office of Chief Counsel, Internal Revenue Service, Washington, D.C., 1984–85; Fellow, American College of Tax Counsel; Academic Fellow, American College of Trust and Estate Counsel.
Incomplete Lifetime Transfers: Retained Powers Under Sections 2036(a)(2) and 2038 (Portfolio 50)Incomplete Lifetime Transfers: Retained Beneficial Interests Under Sections 2036(a)(1) and 2037 (Portfolio 52)Gifts (Portfolio 845)Gifts to Minors (Portfolio 846) Peter A. Lowy, Esq.Peter A. Lowy, J.D. (cum laude and member of law review), Tulane Law School; L.L.M. (taxation), New York University School of Law; member: New York and Texas bars; currently: Senior Tax Counsel, Shell Oil Company; formerly: Senior Tax Attorney, Exxon Mobil Corporation; attorney-advisor, the Honorable Maurice Foley, United States Tax Court; judicial clerk, the Honorable Nauman Scott, U.S. District Court; adjunct professor in Legal Research & Writing, University of Houston Law.
U.S. Federal Tax Research (Portfolio 100)
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Ewing W. Madole, Esq.Ewing W. Madole, B.A., M.B.A. Mississippi State University (1973, 1975); J.D., Columbia University School of Law (1985); LL.M. in Taxation, New York University (1990); Member of the New York Bar; Certified Public Accountant, Tennessee (1977).
Controlled Foreign Corporations — Section 956 (Portfolio 929) Kirk F. Maldonado, Esq.Kirk F. Maldonado, B.A., University of Nebraska at Omaha (1975); J.D., Creighton University (1978); M.L.T., Georgetown University (1981); member, California Bar; Attorney, Employee Plans and Exempt Organizations Division, Office of Chief Counsel, Internal Revenue Service (1978-1981).
Securities Law Aspects of Employee Benefit Plans (Portfolio 362) Peter J. Marathas, Jr. Esq.Peter J. Marathas, Jr., B.A. (1981), cum laude, M.A. (1986), summa cum laude, Bradley University; J.D., magna cum laude, University of Illinois, Harno Fellow (1994); Employment and Labor Section, American Bar Association; Boston Bar Association; Massachusetts Bar (1997), Illinois Bar (1994), Florida Bar (2005).
ERISA — Litigation, Procedure, Preemption and Other Title I Issues (Portfolio 374) Steven R. Mather, Esq.Steven R. Mather, University of Iowa (B.B.A. with highest distinction 1978; J.D., with distinction 1982); Member, California and Iowa Bars; Certified Public Accountant, Iowa, 1979; Senior Attorney, District Counsel, Internal Revenue Service, Los Angeles 1983–87; Co–Director, Tax Court Pro Se Program (Los Angeles/Beverly Hills) 1988–Present; Lecturer, Federal Tax Procedure, Golden Gate University Masters in Taxation Program; Member, Section of Taxation of California, Los Angeles County and Beverly Hills Bar Associations; Contributor, The Tax Lawyer; Co–author: 638-2nd T.M., Federal Tax Collection Procedure.
Audit Procedures for Pass-Through Entities (Portfolio 624)Federal Tax Collection Procedure — Liens, Levies, Suits and Third Party Liability (Portfolio 637)Federal Tax Collection Procedure — Defensive Measures (Portfolio 638) Thomas J. Matragrano, CPAThomas J. Matragrano, J.D., Hofstra University School of Law; B.A., State University of New York at Stony Brook; member, New York State Bar and Tax Section, New York State Bar Association; formerly Attorney/Advisor, Office of Chief Counsel, Internal Revenue Service.
Redemptions (Portfolio 767) James E. MauleJames Edward Maule, B.S., University of Pennsylvania (1973); J.D., Villanova University (1976); LL.M. (Taxation), George Washington University (1979); lecturer, Villanova University Graduate Tax Program and Tax Forum CLE Programs; lecturer, Philadelphia Bar Association Tax Section; member, Advisory Board on U.S. Income, Tax Management Inc.; former attorney-advisor, United States Tax Court, Judge Herbert L. Chabot; former attorney-advisor, Chief Counsel to the Internal Revenue Service; former Editorial Advisory Board member and Columnist, Journal of Limited Liability Companies; former lecturer, ALI-ABA; former lecturer, Tax Management Inc. & Continuing Legal Education Satellite Network; former lecturer, Pennsylvania Bar Institute; former lecturer, Georgetown University Law Center Institute on State and Local Taxation; former lecturer, The Dickinson School of Law CLE Programs; member, American Bar Association, Section of Taxation, Committee on S Corporations (Consultant and former Chair, Subcommittee on Subchapter S and State Law; former Chair, Subcommittee on Comparison of Partnerships and S Corporations).
Gross Income: Overview and Conceptual Aspects (Portfolio 501)Gross Income: Tax Benefit, Claim of Right and Assignment of Income (Portfolio 502)Deductions: Overview and Conceptual Aspects (Portfolio 503)Deduction Limitations: General (Portfolio 504)Trade or Business Expenses and For-Profit Activity Deductions (Portfolio 505)Tax Credits: Concepts and Calculation (Portfolio 506)Income Tax Liability: Concepts and Calculation (Portfolio 507)State, Local, and Federal Taxes (Portfolio 525)Depreciation: MACRS and ACRS (Portfolio 531)Income Tax Basis: Overview and Conceptual Aspects (Portfolio 560)Tax Incentives for Economically Distressed Areas (Portfolio 597)State Taxation of S Corporations (Portfolio 1510) Todd F. Maynes, Esq.Todd F. Maynes, B.A., magna cum laude, Brigham Young University (1984); J.D., magna cum laude, Brigham Young University (1987); law clerk to Judge Kenneth Ripple, United States Court of Appeals for the Seventh Circuit (1987–1988); partner, Kirkland & Ellis LLP, Chicago, Illinois, since 1988; adjunct professor, Chicago-Kent College of Law, Graduate Tax Program, since 1993; chair, Planning Committee of the Chicago-Kent College of Law, Federal Tax Institute.
Start-Up Expenditures (Portfolio 534) Todd Y. McArthur, Esq.Todd Y. McArthur, B.S., University of Virginia, McIntire School of Commerce (1985), Beta Alpha Psi; J.D., University of Virginia, School of Law (1990). Author, Selected Federal Income Tax Issues Arising in Technology Ventures and Business Transactions Involving Technology or Facilitated by the Internet — A Transactional Perspective; with Steven R. Lainoff, “The Final Functional Currency Regime for U.S. Taxpayers Operating in Hyperinflationary Environments: Mandatory DASTM”, 12 Tax Management Int'l J. 583 (1994). Member, Virginia State Bar, District of Columbia Bar, United States Tax Court, and American Bar Association.
Partnership Transactions — Section 751 Property (Portfolio 720) John C. McCoy, Esq.John C. McCoy, B.B.A., University of Notre Dame (1969); J. D., high honors, George Washington University (1976); Arent Fox, LLP since 1976, member since 1984; member, District of Columbia, Virginia, Maryland and American Bar Associations.
Loss Deductions (Portfolio 527)Bad Debts (Portfolio 538) Louis A. Mezzullo, Esq.Louis A. Mezzullo, University of Maryland (B.A. 1967, M.A. 1976), University of Richmond (J.D. 1976); Partner, Luce, Forward, Hamilton & Scripps LLP, 2006 to present; Partner, McGuireWoods LLP, Richmond, Virginia, 2003 to 2006; Member, Mezzullo & Guare, PLC, Richmond, Virginia, 2000 to 2003; Founding Member, Mezzullo & McCandlish, Richmond, Virginia, 1982 to 2000; Adjunct Professor, University of Miami School of Law, University of Richmond Law School.
Fellow and Chair, American College of Tax Counsel; Fellow and former Regent, American College of Trust and Estate Counsel; Charter Fellow, American College of Employee Benefits Counsel; Past Chair, ABA Section of Real Property, Probate and Trust Law (2000-01); former Member of Council, and Current Chair of the Business Planning Subcommittee of the Estate and Gift Taxes Committee of the ABA Section of Taxation; and Academician and Vice President, International Academy of Trust and Estate Law.
Author, An Estate Planner's Guide to Buy-Sell Agreements; An Estate Planner's Guide to Life Insurance; An Estate Planner's Guide to Qualified Retirement Plan Benefits; An Estate Planner's Guide to Family Business Entities; and Valuation Rules Under Chapter 14, all published by the American Bar Association, and Limited Liability Companies in Virginia, published by the Virginia Law Foundation; Co-author, Advising the Elderly Client, published by Clark, Boardman, Callaghan.
The Migrant Client: Tax, Community Property, and Other Considerations (Portfolio 803)Estate Planning for Owners of Closely Held Business Interests (Portfolio 809)Family Limited Partnerships and Limited Liability Companies (Portfolio 812)Estate and Gift Tax Issues for Employee Benefit Plans (Portfolio 814)Valuation of Corporate Stock (Portfolio 831)Transfers of Interests Family Entities Under Chapter 14: Sections 2701, 2703 and 2704 (Portfolio 835)Estate and Gift Tax Issues for Employee Benefit Plans (Portfolio 378)Family Limited Partnerships and Limited Liability Companies (Portfolio 722) Forrest David Milder, Esq.Forrest David Milder, S.B., Massachusetts Institute of Technology (1973) (Phi Beta Kappa); S.M., Massachusetts Institute of Technology (1974); J.D., Harvard Law School (1977); LL.M. (Taxation), Boston University (1983); admitted to bar, Massachusetts; member, Tax Section, American Bar Association, Boston Bar Association (Chairman, Internet and Computer Assisted Tax Practice Committee, former Chairman, Section of Law Office Management and Professionalism); member, National Association of Bond Lawyers; Boston University School of Law, Instructor of Legal Research and Writing; Lecturer, Federal Tax Institute, Massachusetts Continuing Legal Education, Massachusetts Association of Public Accountants, Northwest Center for Professional Education; Contributor on tax matters to The Wall Street Journal, Boston Globe, Massachusetts Banker and Tradesman, The Matrimonial Strategist, Massachusetts Lawyer's Weekly, and Writer's Digest; author of “Disposition of Personal Residence” (The Best of MCLE, August 1991). Contributed Chapter “Federal Income Taxation of Asset Securitization Transactions” to Securitization: Asset–Backed and Mortgage–Backed Securities (Michie 1994).
Rehabilitation Tax Credit and Low-Income Housing Tax Credit (Portfolio 584) Joel E. Miller, Esq.Joel E. Miller, A.B., Columbia College (1954); J.D., Columbia University School of Law (1956); LL.M. in Taxation, New York University Graduate School of Law (1964); Law Secretary to Honorable Harold R. Medina, Judge, U.S. Court of Appeals for the Second Circuit, 1956–1957; associated with Paul, Weiss, Rifkind, Wharton & Garrison, New York, N.Y., 1957–1960; associated with and member of Demov, Morris, Levin & Shein, New York, N.Y., 1961–1969; member of adjunct and full-time faculty, St. John's University School of Law between 1976 and 1989; Chair, Subcommittee on Condominiums and Cooperatives, Committee on Real Estate Tax Problems, Section of Taxation, American Bar Association; Chair, Subcommittee on Liens, Cooperatives and Condominiums Committee, Real Property Law Section. New York State Bar Association, Tax Section; co-author, Modern Trust Forms and Checklists (Warren, Gorham & Lamont, Inc. 1980); author, Federal Taxation of Trusts (Prentice-Hall, Inc., 1968); contributor to Tax Law Review, Journal of Real Estate Taxation, Journal of Taxation and other legal publications on matters involving federal taxation and property law; editor, Real Estate Tax Ideas 1979–1983; member, several advisory boards; and lecturer at various tax institutes. Note: Portions of this portfolio are taken from articles written by Mr. Miller and originally published in the Journal of Real Estate Taxation (Warren, Gorham & Lamont, Inc.).
Cooperative and Condominium Apartments (Portfolio 596) Anne E. Moran, Esq.Anne E. Moran, Partner, Steptoe & Johnson, LLP; B.A., Wellesley College; J.D., Harvard Law School; formerly Tax Counsel, United States Senate Committee on Finance; former member of the ERISA Advisory Council for the United States Department of Labor; member, American Bar Association, Section of Taxation; member, American Bar Association, Joint Committee on Employee Benefits (former chair); member, District of Columbia Bar, Tax Section, Committee on Employee Benefits (former chair) and Steering Committee (former member); member, American College of Employee Benefits Counsel (former board member).
Reasonable Compensation (Portfolio 390)
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Andrew W. Needham, Esq.Andrew W. Needham, J.D., Georgetown University Law Center; LL.M. (Taxation), Georgetown University Law Center; M.B.A., The Wharton School; B.A., University of Arizona; Member, Executive Committee, Tax Section of New York State Bar Association, American Bar Association, United States Tax Court.
Private Equity Funds (Portfolio 735)Hedge Funds (Portfolio 736) Annette NellenAnnette Nellen (B.S., CSU, Northridge; MBA, Pepperdine University; J.D. Loyola Law School) is a Professor of Accounting & Taxation in the College of Business at San José State University, and a Fellow with the New America Foundation.
Amortization of Intangibles (Portfolio 533) Caroline H. Ngo, Esq.Caroline H. Ngo, B.S., University of Virginia (2002); J.D., Cornell Law School (2005); Associate, McDermott Will & Emery LLP (2005-present); member, New York and District of Columbia Bars.
Accumulated Earnings Tax (Portfolio 796)
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Paul W. Oosterhuis, Esq.Paul W. Oosterhuis, B.A., Brown University (1969); J.D., Harvard University (1973); member, Tax Management U.S. Income Advisory Board; member, International Fiscal Association; member, Special Committee on International Tax Policy, U.S. Chamber of Commerce; member, American Bar Association, Section on Taxation, Committee on Foreign Activities of U.S. Taxpayers; Adjunct Professor, Georgetown University Law Center (1977-1983); Legislation Attorney (1973-1977) and Legislation Counsel (1977-1978), Joint Committee on Taxation, U.S. Congress; member, District of Columbia Bar Association.
Research and Development Expenditures (Portfolio 556)
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Jeffrey H. Paravano, Esq.Jeffrey H. Paravano, B.S.B.A., cum laude, John Carroll University; J.D., magna cum laude, Georgetown University Law Center; LL.M. in Taxation, with distinction, Georgetown University Law Center; Firmwide Chair of Baker & Hostetler LLP's Tax, Personal Planning and Employee Benefits Group; formerly, Senior Advisor to the Assistant Secretary, Tax Policy, Department of Treasury; adjunct professor of law (LL.M. program), Case Western Reserve University School of Law and Georgetown University Law Center; member, American Bar Association, Section of Business Law and Section of Taxation; soon-to-be Chair, ABA Tax Section's Affiliated and Related Corporations Committee; former member, Editorial Advisory Boards of Corporate Business Taxation Monthly and The Tax Adviser; Chair, Cleveland International Tax Forum; Editor in Chief, The Tax Lawyer; President, Tax Club; frequent author and speaker on tax topics. Admitted to practice in New York, Connecticut, Ohio, Colorado, Maryland, and Washington, D.C.
Tax Shelters (Portfolio 798) Gordon O. Pehrson, Jr. Esq.Gordon Pehrson, a partner in the Washington office of Hopkins & Sutter, is a nationally recognized expert on the taxation of insurance companies and their products. Mr. Pehrson is a graduate of the College of William & Mary (A.B. 1964) and the University of Michigan School of Law (J.D. cum laude 1967), where he was elected to the Order of the Coif. From 1977 through 1981, Gordon was an adjunct professor of law in the graduate tax program at Georgetown University. In 1990, he was elected as a member of the American Law Institute.
Annuities, Life Insurance, and Long-Term Care Insurance Products (Portfolio 546) Dennis L. Perez, Esq.Dennis L. Perez, A.B., San Diego State University (1978); J.D., University of California at Los Angeles (1982). Trial Attorney, District Counsel, Internal Revenue Service (1982–1986). Member: American Bar Association, State Bar of California. Principal – Hochman, Salkin and DeRoy, P.C., Beverly Hills, California.
Tax Crimes (Portfolio 636) Theodore D. Peyser, Esq.Theodore D. Peyser, B.A., Princeton University (1950); LL.B., Yale Law School (1955); member, District of Columbia, Tax Court, Court of Federal Claims, Federal Circuit, and U.S. Supreme Court Bars; member, Court Procedure Committee, Tax Section, ABA; Tax Division, U.S. Department of Justice, trial attorney (1955-1973), chief, Claims Court Section (1974-1984), Special Litigation Counsel (1985-1987); author, 631-2nd T.M., Refund Litigation and 628-2nd T.M. Transferee Liability; co-author, 630-3rd T.M. Tax Court Litigation; contributor, Tax Practice Series.
Limitations Periods, Interest on Underpayments and Overpayments, and Mitigation (Portfolio 627)Transferee Liability (Portfolio 628)Refund Litigation (Portfolio 631)Tax Court Litigation (Portfolio 630) Barnet Phillips, IV Esq.Barnet Phillips, IV, Partner, Skadden, Arps, Slate, Meagher & Flom L.L.P., New York, New York; B.A., Yale University 1970; J.D., Fordham University 1973; LL.M., New York University 1977.
Structuring Corporate Acquisitions — Tax Aspects (Portfolio 770) David W. Powell, Esq.David W. Powell, B.B.A., cum laude, Southern Methodist University (1979); J.D., University of Texas School of Law (1982); member: Tax section of the American Bar Association, District of Columbia Bar, New York State Bar, State Bar of Texas, Louisiana State Bar; Certified Public Accountant, Louisiana (1983).
Church and Governmental Plans (Portfolio 372)
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Thomas Z. Reicher, Esq.Thomas Z. Reicher, Amherst College (B.A. summa cum laude and Phi Beta Kappa, 1970); University of California at Berkeley (M.A. 1973); Stanford University Law School (J.D. 1976); member, Connecticut Bar; Director, New England Employee Benefits Council; partner, Day, Berry & Howard.
Statutory Stock Options (Portfolio 381)Reductions Force (Portfolio 398) Richard Reichler, Esq.Mr. Reichler was formerly an Attorney Advisor, Office of the Chief Counsel Internal Revenue Service in Washington, D.C. and Vice President, Tax Planning and Services and Deputy General Counsel, of the Long Island Lighting Company. He also acted as the National Director of Executive Compensation Planning while a Senior Tax Partner at Ernst & Young, P.C.'s New York office. He is currently with the law firm of Meltzer, Lippe, Goldstein & Breitstone, LLP. Mr. Reichler is a 1955 graduate of Columbia College and a 1957 graduate of Columbia University Law School. He is a member of the New York State Bar Association (Tax Section), the International Fiscal Association, and the BNA Tax Management Advisory Board. Mr. Reichler is the author of “Leveraged Buyout Financing in Business Combinations and Restructuring,” and “The Limited Partnership as an Investment Vehicle.”
State Taxation of Compensation and Benefits (Portfolio 366)State Taxation of Compensation and Benefits (Portfolio 1750) Taylor S. Reid, Esq.Taylor S. Reid, Esq., B.A., University of California at Berkeley (1986); Graduate Diploma in International Studies, University of Vienna, Austria (1990); J.D., Northwestern University School of Law (1993, cum laude); Partner, Baker & McKenzie LLP; co-author, Internet Law for the Business Lawyer (ABA: 2001); co-author, United States Taxation of Income Derived from International Electronic Commerce Transactions, Tax Management Memorandum (December 4, 2000); member, State Bar of California, Illinois State Bar Association, American Bar Association Section on Taxation.
Federal Taxation of Software and E-Commerce (Portfolio 555) Charles P. Rettig, Esq.Charles P. Rettig, B.A., University of California at Los Angeles (1978); J.D., Pepperdine University (1981); LL.M., New York University (1982). Member: American Bar Association, State Bar of California, State Bar of Arizona. Principal – Hochman, Salkin and DeRoy, P.C., Beverly Hills, California.
Tax Crimes (Portfolio 636) Donald B. Reynolds, Jr. Esq.
Donald B. Reynolds, Jr., shareholder, Buchanan Ingersoll & Rooney PC; J.D., magna cum laude, 1979, Georgetown University Law Center; senior case and note editor, Law and Policy in International Business; B.A., magna cum laude, 1976, Hamilton College. Mr. Reynolds focuses his practice on financings, acquisitions and business planning for a variety of businesses, including both closely and widely held entities. His clients include mortgage companies, real estate brokerage firms, insurance companies and real estate developers. Reynolds specializes in tax and business and international tax. He is admitted to District of Columbia. Mr. Reynolds has represented the largest privately-held real estate brokerage firm in the country in virtually all of its significant acquisitions and financings. In addition to the brokerage business, the client's subsidiaries operate mortgage, title insurance and casualty insurance businesses. Along with his transactional work, Don also specializes in tax planning for partnerships, limited liability companies and S corporations and is a frequent contributor to tax publications and tax conferences.
Tax Shelters (Portfolio 798) Candace A. Ridgway, Esq.Candace A. Ridgway, B.A. (cum laude), University of Connecticut; M.B.A., Arizona State University; J.D. (magna cum laude), Cornell Law School; LL.M. (Taxation, with distinction), Georgetown University Law Center; member, District of Columbia Bar; member, New York State Bar; member, American Bar Association, Tax Section, Corporate Tax Committee.
Corporate Bankruptcy (Portfolio 790)Corporate Separations (Portfolio 776)Corporate Acquisitions — D Reorganizations (Portfolio 772) Jeffrey I. Rosenberg, Esq.Jeffrey I. Rosenberg, undergraduate degree, University of Rhode Island; J.D., Western New England College School of Law; LL.M. in Taxation, Georgetown University Law Center; formerly Attorney-Advisor, Passthroughs and Special Industries Division of the Office of Chief Counsel, Internal Revenue Service; speaker and lecturer, various tax institutes; author, various articles on tax issues in partnership area.
Limited Liability Companies (Portfolio 725) Howard J. Rothman, Esq.Howard J. Rothman, B.A., City College of New York (1967); J.D., Brooklyn Law School (1971); LL.M., New York University School of Law (1972); member, American Bar Association, Section of Taxation, Committee on Corporate Tax; member, New York State Bar Association, Section of Taxation, Committee on Corporations, Committee on Partnerships, and Committee on Income from Real Property; member, International Bar Association, Committee on Taxation; Advisory Board, Tax Management Real Estate Journal; member, New York State Bar; co-author, Tax Management Portfolios No. 561, Capital Assets and No. 759, Transfers to Controlled Corporations: Related Problems.
Capital Assets (Portfolio 561)Transfers to Controlled Corporations: General (Portfolio 758)Transfers to Controlled Corporations: Related Problems (Portfolio 759) Robert P. Rothman, Esq.Robert P. Rothman, Of Counsel, Piper Rudnick L.L.P., New York, New York; B.S., Cornell University 1978; J.D., Columbia University 1981; Formerly associated with Skadden, Arps, Slate, Meagher & Flom L.L.P., New York, New York.
Structuring Corporate Acquisitions — Tax Aspects (Portfolio 770)
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Michael H. Salama, Esq.Michael H. Salama, B.S. (Mathematics), Vassar College (Ford Foundation Scholar); J.D. (with honors), George Washington University Law School. Vice President Tax Administration & Senior Tax Counsel for The Walt Disney Company. Previous positions include: senior manager, the Washington National Tax Services group, PricewaterhouseCoopers LLP; senior trial attorney, Office of Chief Counsel, IRS Active member of the American Bar Association's Tax Accounting Committee. Previous professional organization activities include: Chair, Los Angeles County Bar Association's Entertainment Tax Committee; member, IRS Commissioner's Advisory Council; member, Georgetown University State & Local Tax Institute Advisory Board; member, UCLA Tax Controversy Institute Planning Committee.
Film Production: Basis Recovery and Federal Incentives (Portfolio 599) Bruce S. Schaeffer, Esq.Bruce S. Schaeffer, Master of Laws (Taxation), New York University School of Law, 1976; J.D., Brooklyn Law School, 1975. Mr. Schaeffer is an attorney in private practice with offices in New York, N.Y. He concentrates his practice in the areas of estate planning, taxation, franchising, and securities fraud. Mr. Schaeffer is also president of Franchise Valuations Limited and is a member of the Institute of Business Appraisers.
Tax Aspects of Franchising (Portfolio 559) J. Ronald SchiffJ. Ronald Shiff, B.S., University of Maryland; J.D., Georgetown University Law Center; LL.M. Taxation, Georgetown University Law Center; Adjutant Professor of Law, University of Baltimore; Member, The Bar Association of Baltimore City (Chair, Budget & Finance Committee); Maryland State Bar Association (Section of Taxation, Past Chairman); American Bar Association (Tax Section, Corporate Tax Committee, Regulated Investment Company Committee); author of various tax articles.
David M. SchizerDavid M. Schizer is the Dean and Lucy G. Moses Professor of Law at Columbia Law School, where he teaches courses on federal income taxation, the taxation of financial instruments, corporate tax, and the economics of transactions. His publications include: “Frictions and Tax-Motivated Hedging: An Empirical Exploration of Publicly-Traded Exchangeable Securities,” 56 National Tax J. 167 (Mar. 2003) (with William Gentry); “Understanding Venture Capital Structure: A Tax Explanation for Convertible Preferred Stock,” 116 Harv. L. Rev. 874 (2003) (with Ronald Gilson); “Reducing the Tax Cost of Indexed Options,” 96 Tax Notes 1375 (9/2/02); “Frictions as a Constraint on Tax Planning,” 102 Colum. L. Rev. 1312 (2001); “Tax Constraints on Indexed Options,” 149 U. Pa. L. Rev. 1941 (2001); “Sticks and Snakes: Derivatives and Curtailing Aggressive Tax Planning,” 73 S. Cal. L. Rev. 1339 (2000); “Executives and Hedging: The Fragile Legal Foundation of Incentive Compatibility,” 100 Colum. L. Rev. 440 (2000); and “Realization as Subsidy,” 73 N.Y.U. L. Rev. 1549 (1998). Dean Schizer has also written several reports for the New York State Bar Association, where he serves on the executive committee and as co-chair of the Committee on Financial Institutions. Dean Schizer is also a member of the Tax Club and the Tax Forum. He served in the tax department at Davis Polk & Wardwell from 1995-98, and clerked for Justice Ruth Bader Ginsburg during the U.S. Supreme Court's October 1994 term. He is a graduate of Yale College and Yale Law School.
Financial Instruments: Special Rules (Portfolio 186) John G. Schmalz, Esq.John G. Schmalz, B.A., University of Wisconsin, Milwaukee; J.D., Marquette University; formerly Attorney-Advisor, Legislation and Regulations Division, Office of the Chief Counsel, Internal Revenue Service; member, American Bar Association, Tax Section (Partnership Committee), State Bar of Wisconsin; Vice Chairman, ABA Partnership Tax Committee's Subcommittee on like-kind exchanges; author, articles published in Journal of Partnership Taxation, Journal of Taxation, Journal of Real Estate Taxation, and Journal of S Corporation Taxation.
Limited Liability Companies (Portfolio 725) John W. Schmehl, Esq.John W. Schmehl, B.A., Muhlenberg College (cum laude, 1975); J.D., Dickinson School of Law (cum laude, 1978); Editor, Dickinson Law Review; LL.M. (Taxation), Temple University School of Law (1982); former Trial Attorney, Office of Chief Counsel, Internal Revenue Service; author and lecturer on various tax topics concerning corporate tax and tax procedure.
Compelled Production of Documents and Testimony Tax Examinations (Portfolio 633)Responsible Person and Lender Liability for Trust Fund Taxes — Sections 6672 and 3505 (Portfolio 639) Mark N. Schneider, Esq.Mark N. Schneider, B.S., Lehigh University, magna cum laude (1971); M.B.A., Columbia University (1973). Certified Public Accountant (California, DC, New York and Texas); Partner, Deloitte Tax LLP; member, American Institute of Certified Public Accountants, National Association of Real Estate Investment Trusts, American Society of Pension Professionals & Actuaries; AICPA Tax Practice Responsibilities Committee; and former member of the AICPA Employee Benefits Tax Committee.
Real Estate Investment Trusts (Portfolio 742) Daniel J. Schwartz, Esq.Daniel J. Schwartz, University of Missouri at Columbia (A.B. 1974 cum laude); University of Missouri at Kansas City (J.D. 1977); Member of the Bar Association of Metropolitan St. Louis, the Missouri Bar, and the American Bar Association Section of Taxation, Committee on Employee Benefits.
Employee Benefits for Tax-Exempt Organizations (Portfolio 373) David H. ShapiroDavid H. Shapiro, A.B., cum laude, Princeton University (1992); J.D., University of Virginia School of Law (1995); LL.M. (Taxation), New York University School of Law (1997). Editor, Virginia Tax Review (1994-95); Graduate Editor, Tax Law Review (1996-97). Adjunct Professor of Law, Georgetown University Law Center. Member: New York State Bar, District of Columbia Bar, American Bar Association (Tax Section) and District of Columbia Bar Association (Tax Section).
Taxation of Equity Derivatives (Portfolio 188) Daniel N. ShaviroDaniel N. Shaviro, A.B., Princeton University (1978); J.D., Yale Law School (1981); member, District of Columbia Bar; author of various books including When Rules Change: A Political and Economic Analysis of Retroactivity and Transition Relief and Making Sense of Social Security Reform; contributor of articles to various journals including Tax Law Review, Virginia Tax Review, TAXES, Harvard Law Review, University of Chicago Law Review, and Michigan Law Review; Caplin & Drysdale, Washington D.C. (1981–84); Legislation Attorney, Joint Committee on Taxation (1984–87); Assistant Professor and then Professor of Law at University of Chicago Law School (1987-1995); Professor of Law at NYU Law School since 1995.
Passive Loss Rules (Portfolio 549) Gary J. Silversmith, Esq.Gary J. Silversmith, B.S., magna cum laude, University of Colorado (1977); J.D., Georgetown University Law Center, member, The Journal of Law & Policy, (1981); M.L.T., Georgetown University Law Center (1983); member: District of Columbia Bar Association, Colorado Bar Association, American Bar Association, Sections of Taxation and Real Estate; Vice President—Long & Foster Real Estate, Inc., Washington, D.C.; formerly, The Office of the General Counsel, Federal National Mortgage Association; guest lecturer at Johns Hopkins University; contributor to various legal publications.
REMICs, FASITs and Other Mortgage-Backed Securities (Portfolio 741) Horacio E. Sobol, CPAHoracio E. Sobol, B.B.A. University of Michigan, M.Acc. University of Michigan; Member AICPA; contributor to various tax journals and lecturer at various tax seminars.
S Corporations: Operations (Portfolio 731) Gary D. Sprague, Esq.Gary D. Sprague, Esq., B.A., Stanford University (1977, with honors; Phi Beta Kappa); J.D., Harvard Law School (1981, cum laude); Partner, Baker & McKenzie, LLP; Business Co-Chair of OECD Technical Advisory Group on Treaty Characterization Issues arising from E-Commerce; Business Co-Chair of OECD Technical Advisory Group on Monitoring the Application of Existing Treaty Norms for the Taxation of Business Profits; co-author, Source of Royalty Income and Place of Use of Intangible Property, Tax Management International Journal (August 2007); co-author, Permanent Establishments and Internet-Enabled Enterprises: The Physical Presence and Contract Concluding Dependent Agent Test, Georgia Law Review (Fall 2003); author, Application of Transfer Pricing Rules to Branches and Permanent Establishments—Electronic Commerce and Intangible Property Aspects, The George Mason Law Review (Summer 2002); co-author, General Report on Main Subject I: Taxation of Income Derived from Electronic Commerce, Cahiers de Droit Fiscal International (2001); co-author, United States Taxation of Income from International Electronic Commerce Transactions, Tax Management Memorandum (December 2000); co-author, The Final Software Revenue Characterization Regulations, Tax Management International Journal (February 1999); co-author, Characterization of Computer Software Revenue in International Transactions, TAXES (December 1996); member of American Bar Association; International Fiscal Association, USA Branch; State Bar of California.
Federal Taxation of Software and E-Commerce (Portfolio 555) Lisa M. Starczewski, Esq.Lisa Marie Starczewski, Smith College, B.A. (magna cum laude, 1985); Villanova University School of Law, J.D. (summa cum laude, 1988); Editor-in-Chief, Villanova Law Review (1987-88); member of adjunct faculty, Villanova University School of Law; former associate, Morgan, Lewis & Bockius; Schnader, Harrison, Segal & Lewis; author, 714 T.M., Partnerships — Allocation of Liabilities; Basis Rules; 550 T.M., At-Risk Rules; 565 T.M., Installment Sales; 621 T.M., IRS National Office Procedures — Rulings, Closing Agreements; co-author, 517 T.M., Scholarships and Educational Expenses; 5100 T.M., Revenue Recognition: Fundamental Principles (Accounting Series); 5101 T.M., Revenue Recognition: Product Sales and Services (Accounting Series); 5114 T.M., Accounting for Leases: Fundamental Principles (Accounting Series); 5117 T.M., Leases: Lessee Perspective (Accounting Series); 5118 T.M., Leases: Lessee Perspective — Selected Topics (Accounting Series); author of several chapters in the Tax Practice Series and contributor to various tax publications; recipient of Distinguished Author award; member, Tax Management U.S. Income Advisory Board.
Revenue Recognition: Fundamental Principles (Portfolio 5100)Accounting for Leases: Fundamental Principles (Portfolio 5114)Leases: Lessee Perspective (Portfolio 5117)Leases: Lessee Perspective — Selected Topics (Portfolio 5118)Leases: Lessor Perspective — Economics (Portfolio 5120)Leases: Lessors - Classification (Portfolio 5128)Revenue Recognition: Software (Portfolio 5103)Revenue Recognition: Product Sales and Service (Portfolio 5101)Scholarships and Educational Expenses (Portfolio 517)At-Risk Rules (Portfolio 550)Installment Sales (Portfolio 565)Noncorporate Alternative Minimum Tax (Portfolio 587)IRS National Office Procedures — Rulings, Closing Agreements (Portfolio 621)Partnerships — Allocation of Liabilities; Basis Rules (Portfolio 714)Corporate Alternative Minimum Tax (Portfolio 752) Samuel P. Starr, CPA Esq.Samuel P. Starr, B.S., Pennsylvania State University; J.D., University of Virginia; LL.M. in Taxation, Georgetown University Law Center; former member, AICPA, Partnership Tax Committee; former Chair, AICPA S Corporation Committee; former Co-Chair, ABA Tax Section Task Force on Taxable and Tax-Free Acquisitions Involving S Corporations; Adjunct Professor, Georgetown University Law Center; member, Board of Advisors, Journal of Business Entities; Department Editor, Journal of Taxation; speaker and lecturer, various tax institutes; author, Tax Management Portfolios 730-2nd and 731; member, State Bars of Pennsylvania and District of Columbia.
Limited Liability Companies (Portfolio 725)S Corporations: Formation and Termination (Portfolio 730)S Corporations: Operations (Portfolio 731) Ira B. Stechel, Esq.Ira B. Stechel, B.A., magna cum laude, City College of New York (1969); J.D., Cornell Law School (1972); Note Editor, Cornell International Law Journal (1971–72); LL.M. (Taxation), New York University; member, Connecticut Bar, New York Bar; American Bar Association (Section of Taxation); New York State Bar Association (Tax Section), Committee on Corporations, Committee on Partners and Partnerships; author, 519 T.M., Travel and Transportation Expenses — Deduction and Recordkeeping Requirements; contributor, Journal of Taxation, Taxation for Lawyers, Taxation for Accountants, Tax Management Real Estate Journal, Tax Ideas; lecturer, N.Y.U. Institute on Federal Taxation, Midwest Tax Institute and Fordham Law School.
Travel and Transportation Expenses — Deduction and Recordkeeping Requirements (Portfolio 519)Entertainment, Meals, Gifts and Lodging — Deduction and Recordkeeping Requirements (Portfolio 520) Christopher G. Stoneman, Esq.Christopher G. Stoneman, B.A. (law), Cambridge University (1949); LL.B., University of Virginia (1957); M.A., New York University (1989); member, New York and Vermont Bars; lecturer, Vermont Law School (1986–1995); fellow, American College of Trusts and Estates Counsel; author of several Portfolios in the estate planning field.
Deductibility of Legal and Accounting Fees, Bribes and Illegal Payments (Portfolio 523)Deductibility of Illegal Payments, Fines, and Penalties (Portfolio 524)Gross Estate — Section 2033 (Portfolio 817)Private Foundations — Excess Business Holdings (Portfolio 881) William P. StrengWilliam P. Streng, Wartburg College (B.A., 1959); Northwestern University School of Law (J.D., 1962); Law Clerk to Honorable Lester L. Cecil, Chief Judge, U.S. Court of Appeals for the Sixth Circuit, 1963-1964; associated with Taft, Stettinius & Hollister, Cincinnati, Ohio, 1964-1970; Attorney-Advisor, Office of the Assistant Secretary for Tax Policy (Office of Tax Legislative Counsel), U.S. Dept. of the Treasury, Washington, D.C., 1970-1971; Deputy General Counsel, Export-Import Bank of the United States, Washington, D.C., 1971-1973; Professor of Law, School of Law, Southern Methodist University, Dallas, Texas, 1973-1980; Visiting Professor, College of Law, The Ohio State University, 1977; Haynes & Boone, Dallas, Texas (Of Counsel, 1977-1979); Bracewell & Patterson (now Bracewell & Giuliani), Houston, Texas (partner, 1980-1985; Consultant, 1985-); Professor of Law, University of Houston Law Center (1985-); Visiting Professor, New York University School of Law (1990); Distinguished Lecturer at the University of Hong Kong Law Faculty (1992); Fulbright Professor at the University of Stockholm Law Faculty, Stockholm, Sweden (1993); Visiting Fellow at the Victoria University Law Faculty, Wellington, New Zealand (1996); Lecturer, U.S. International Taxation, University of Leiden, The Netherlands (1997 & 1998 and 2000); Visiting Professor, The University of Texas School of Law (2002); Visiting Professor, Department of International and Business Law, International Graduate School of Social Sciences, Yokohama National University, Japan (2005).
Member of American Law Institute (including its Tax Advisory Group), International Fiscal Association (including its Council), International Academy of Estate and Trust Law, American Bar Association's Section of Taxation, Tax Management Advisory Board, and various other professional organizations.
Mr. Streng is the author of the following books and portfolios: 800 T.M. Estate Planning (Tax Management, 2005), and prior versions of this Estate Planning Portfolio; Prior versions of this 700 T.M. Choice of Entity portfolio (Tax Management, 1997); “U.S. International Estate Planning” (RIAG-Warren, Gorham & Lamont, 1996), and subsequent revisions in print and on RIA Checkpoint; “International Business Transactions — Tax and Legal Handbook” (Prentice-Hall, 1978); “Estate Planning — Principles, Techniques and Materials” (Tax Management, 1981). Mr. Streng is the co-author of: Bittker, Emory & Streng, “Federal Income Taxation of Corporations and Shareholders — Forms,” 4th ed. (Warren, Gorham & Lamont, 1995, with supplements through 2005); Streng & Salacuse, “International Business Planning — Law and Taxation,” six volumes (Matthew Bender, 1982, 1985, 1986, and supplements through 2005); Streng & Davis, “Tax Planning for Retirement” (RIAG-Warren, Gorham & Lamont, revised edition 2005); Gifford & Streng, “International Tax Planning” (Tax Management, 1979); and, Streng & Wilcox, “Doing Business in China,” (Matthew Bender, 1990, and subsequent supplements).
Choice of Entity (Portfolio 700)Estate Planning (Portfolio 800)
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Alan J. Tarr, Esq.Alan J. Tarr, B.S., Brown University (1975); J.D., Vanderbilt University School of Law (1979); M.B.A., Vanderbilt University Graduate School of Management (1979); LL.M. (Taxation), New York University School of Law (1982); member, New York Bar, New York State Bar Association (Tax Section; Executive Committee (1995-2004); former co-chair, various committees); American Bar Association (Tax Section; Vice-Chair, Real Property, Probate and Trusts Committee on Federal Taxation of Real Property (2004- ); and New York City Bar Association (Tax Section; Committee on Taxation of Business Entities (2007- ); member, Tax Management Advisory Board; author, “Estimated Tax,” “Formation of a Corporation,” “Capitalization of a Corporation,” “Multiple Corporations,” and “Stapled Entities” for Tax Practice Series; co-author, 59 T.M., Corporate Liquidations: Planning and 634 T.M., Civil Tax Penalties; contributor, various journals.
Estimated Tax (Portfolio 581)Civil Tax Penalties (Portfolio 634) William Tatlock, Esq.William Tatlock, B.A., Yale University (1956); LL.B., Harvard University (1959); LL.M. (Taxation), New York University (1977); member, New York City, New York State, New Jersey, and American Bar Associations.
Discharge of Indebtedness, Bankruptcy and Insolvency (Portfolio 540) Charles B. TemkinCharles B. Temkin, Esq., B.A., Columbia University, summa cum laude (1969); J.D., Harvard University, magna cum laude (1972). Attorney advisor, U.S. Dept. of the Treasury, Office of Tax Legislative Counsel (1974-1976). Director, Deloitte Tax LLP; member, American Bar Association Section of Taxation, National Association of Real Estate Investment Trusts; D.C. Bar Taxation Section, member, Steering Committee (1989-1994), Vice-Chair and then Chair, Pass-Through Entities and Real Estate Committee (1996-2001).
Real Estate Investment Trusts (Portfolio 742) Dennis J. Tingey, J. D. CPADennis L. Tingey, B.S. Arizona State University, M.S.T., Arizona State University, J.D. Arizona State University College of Law; member American Bar Association, Tax Section; member State Bar of Arizona; member, American Institute of Certified Public Accountants.
Accounting Methods — Adoption and Changes (Portfolio 572) Steven R. Toscher, Esq.Steven R. Toscher, B.S.B.A., University of Nevada (1975); J.D., University of San Diego (1979). Trial Attorney, Tax Division, U.S. Department of Justice (1979–1983). Member: American Bar Association, State Bar of California. Principal – Hochman, Salkin and DeRoy, P.C., Beverly Hills, California.
Tax Crimes (Portfolio 636) Barry A. TovigBarry A. Tovig, B.S., magna cum laude, Montclair State University; member, AICPA – Chair, Tax Accounting Technical Resource Panel; member, D.C. Institute of CPAs; formerly with Internal Revenue Service as Tax Law Specialist, Office of Chief Counsel, Corporation Tax (1981–1986) and Internal Revenue.
Inventories: General Principles; LIFO Method (Portfolio 578) Christine M. Turgeon, CPAChristine M. Turgeon, B.B.A., Baylor University; B.S. in Taxation, American University; partner, Washington National Tax Services office of PricewaterhouseCoopers LLP; formerly of Office of Tax Legislative Counsel, U.S. Department of the Treasury (1998-2002), served as Senior Tax Law Specialist specializing in accounting methods and inventories; member, American Institute of Certified Public Accountants Technical Resource Panel on Accounting Methods.
Accounting for Long-Term Contracts (Portfolio 575)
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Marcia S. Wagner, Esq.Marcia Beth Stairman Wagner, B.A., summa cum laude, Cornell University (1984); J.D., Harvard Law School (1987), Law and Economics Fellow; Employee Benefits Committee of American Bar Association Tax Section; Tax Section Counsel, Massachusetts Bar Association; Pension Liaison Committee, IRS Key District Office, Brooklyn, New York; Massachusetts and District of Columbia Bars (1987).
ERISA — Litigation, Procedure, Preemption and Other Title I Issues (Portfolio 374)EPCRS — Plan Correction and Disqualification (Portfolio 375) James C. Warner, Esq.James C. Warner, B.A., Grove City College (1971); J.D. (cum laude; law journal editor), The Ohio State University College of Law (1974); CPA, Maryland (1979); LL.M. in Taxation (1st in class) Georgetown University Law Center (1979); Attorney-Advisor, Interpretative Division, Office of Chief Counsel, Internal Revenue Service (1974-77); Attorney-Advisor, Judge William M. Drennen, U.S. Tax Court (1978-79); Partner and Associate, Lee, Toomey, and Kent (1979-1993); Adjunct Professor, Georgetown University Law Center (1992-1994); President, USA Tax Videos (1994-1996); author, Consolidated Returns Guide (CCH, 2003); Mergers & Acquisitions Segment Leader, Ernst & Young's Online Tax Advisor (1999-2004); Senior Director, Tax Research & Planning, Wal-Mart Stores, Inc. (2004-present).
Accumulated Earnings Tax (Portfolio 796)Corporate Overview (Portfolio 750) David A. Weintraub, Esq.David A. Weintraub, B.S., Accounting, cum laude, State University of New York at Buffalo (1976); M.B.A., State University of New York at Buffalo (1977), J.D., magna cum laude, Albany Law School of Union University (1993); L.L.M. in Taxation, New York University (1994); Associate, Roberts & Holland LLP, Washington, District of Columbia; member, New York, District of Columbia, and U.S. Tax Court bars, editor, Albany Law Review, 1991-1992, co-author, articles on real estate taxation, including the Journal of Taxation and BNA publications.
Tax Court Litigation (Portfolio 630) Thomas S. Welk, Esq.Thomas S. Welk, University of Washington (B.A. 1983); Gonzaga University Law School (J.D. cum laude, 1989); New York University School of Law (LL.M., Taxation, 1990); member, California Bar; partner, Cooley Godward Kronish LLP.
Statutory Stock Options (Portfolio 381) Richard A. Westin, Esq.Richard A. Westin, B. A., Columbia University (1967); M.B.A., Columbia University (1968); J.D., University of Pennsylvania Law School; member, Kentucky Bar Association; Tax Bar Association, Court of Claims, Tax Court; Distinguished University Professor, University of Kentucky College of Law (1994-98); Foundation Professor, University of Houston Law Center (1983-84); visiting professor, University of Tennessee Law School (1979-83); Associate Professor, Chicago-Kent College of Law; former consultant to Legal Department of International Bank for Reconstruction and Development, Washington, D.C.; research fellow at University of Dundee, Petroleum and Mineral Law Centre (1992); author of 603 T.M., Mineral Properties Other Than Gas and Oil — Operation; RIA Tax Dictionary (2006-07 ed.); Taxation of International Electronic Commerce (with McNulty and Beck) (2d ed. 2007); Federal Income Taxation of Natural Resources (PLI 1994); Taxation for Environmental Protection, a Multinational Study (with Gaines, Tiley, Erikkson, Von Zezchewitz and Hertzog) (1991).
Mineral Properties — Exploration, Acquisition, Development and Disposition (Portfolio 601)Mineral Properties Other Than Gas and Oil — Operation (Portfolio 603) Gary B. Wilcox, Esq.Gary B. Wilcox, LL.M. (Taxation), New York University School of Law; J.D. (with highest honors), University of Oklahoma; B.B.A. (cum laude), Texas Tech University; former Deputy Chief Counsel, Internal Revenue Service; former Partner, PricewaterhouseCoopers, Washington National Tax Services; member, District of Columbia Bar and Pennsylvania Bar.
Corporate Acquisitions — (A), (B), and (C) Reorganizations (Portfolio 771) Donald T. Williamson, Esq.Donald T. Williamson, B.A. (Phi Beta Kappa), Hamilton College (1973); M.B.A., Johnson Graduate School of Business Administration, Cornell University (1976); J.D., Cornell Law School (1977); LL.M., Georgetown University Law Center (1983); Associate Editor, The Tax Lawyer, 1982–1983; Certified Public Accountant (Virginia, 1979); principal, LaMonaca & Williamson, CPAs, Falls Church, Virginia.
The Investment Credit and Cost Segregation (Portfolio 583) Bill C. WilsonBill C. Wilson, Partner, Executive Compensation Tax Services, Deloitte & Touche LLP; CPA; B.S., Cum Laude, University of Southern California. From June, 2002, a retired partner and a consultant to Deloitte & Touche.
Golden Parachutes (Portfolio 396) Cindy Lynn Wofford, Esq.Cindy Lynn Wofford is a principal in the law firm of Ravdin & Wofford. Ms. Wofford has practiced tax and estate planning for 20 years and domestic relations for 10 years. Prior to joining Ravdin & Wofford, Ms. Wofford was with the National Office of Chief Counsel, IRS, Tax Litigation Division, and in private practice with law firms in Dallas and Houston. A graduate of the University of Texas School of Law, Ms. Wofford received her master of laws degree in taxation from Southern Methodist University School of Law.
Divorce and Separation (Portfolio 515) Robert W. Wood, Esq.Robert W. Wood is a 1979 graduate of University of Chicago Law School where he earned a Juris Doctor and won the Florence James Adams Prize as well as a University of Chicago Scholarship. He practices law with Wood & Porter in San Francisco, California where he provides services for domestic and international clients on a variety of state, federal, and international tax matters. Mr. Wood is admitted to practice law in CA, NY, AZ, MT, WY, and DC. He is also admitted to practice as a Solicitor in England and Wales. Mr. Wood is a tax expert and has been designated by the State Bar of California as a Certified Specialist in Taxation. Mr. Wood is the author of 31 books in the field of taxation. He has long been recognized as a leading authority and commentator on several highly specialized and complex areas of the tax law. He is one of the foremost experts in the world on the taxation of damage awards and settlement payments. Mr. Wood frequently serves as a counselor and expert witness to his clients throughout the world on this unique area of the tax law and is the author of the leading treatise in the area, Taxation of Damage Awards and Settlement Payments (published by Tax Institute). Mr. Wood is also the founder and Editor-in-Chief of The M&A Tax Report, a national monthly newsletter addressing tax techniques and trends affecting mergers and acquisitions.
Tax Aspects of Settlements and Judgments (Portfolio 522)Home Office, Vacation Home, and Home Rental Deductions (Portfolio 547)Hobby Losses (Portfolio 548)Real Estate Mortgages (Portfolio 592)
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Lisa M. Zarlenga, Esq.Lisa M. Zarlenga, Esq., B.S., Ohio State University (1991); J.D., Ohio State University College of Law (1994); LL.M. (Taxation), Georgetown University Law Center (1997). Law Clerk to the Honorable Robert P. Ruwe, U.S. Tax Court, 1994-96; Partner, Steptoe & Johnson LLP, Washington, D.C.; member, American Bar Association, Tax Section — Corporate Tax Committee (Chairman of Subcommittee on Liquidations and Taxable Distributions), Government Relations Committee; 2004-2005, John S. Nolan Tax Law Fellow; District of Columbia Bar, Taxation Section — Steering Committee (member), Corporate Tax Committee (Chairman), Federal Bar Association, Tax Section; member, District of Columbia Bar and State Bar of Ohio.
Disregarded Entities (Portfolio 704)