Insights & Commentary The following are selected comments by leading tax authorities on a variety of current tax issues. Extensive collections of current commentary are contained in BNA Tax Management’s news publications and specialized journals.
Release of Form 990 Draft Instructions ,
By Elizabeth Carrott Minnigh, Esq....May 2008
Section 403(b) Plans for Tax-Exempt Employers--the Collective
Bargaining Dilemma ,
By Carol H. Jewett, Esq. and Felicia A. Finston, Esq....April 2008
IRS Agents Reprimanded ,
By Nicholas S. Curabba, Esq....April 2008
Should a Nonresident Alien Make a §83(b) Election? (And Some
More Musings on FIRPTA) ,
By Kimberly S. Blanchard, Esq....April 2008
Early Application of Proposed §987 Regulations May Be Blessed
by the IRS--But Is It a Good Idea? ,
By James J. Tobin, Esq....April 2008
Proposed Contract Manufacturing Regulations and Pablo Picasso ,
By Kenneth J. Krupsky,
Esq....April 2008
Swallows Revisited
Practitioner’s Forum Discussion: LaRue v. DeWolff, Boberg
& Associates, Inc., 502 U.S. __, 128 S. Ct. 1020, 42 EBC 2857
(2008) ,
By Stuart M. Lewis, Dan S. Brandenburg, Annemarie G. McGavin, and Seth H. Tievsky...April 2008
The AMT and Stock Options: Taxpayers Continue to Lose in the
Appellate Courts ,
By Lisa M. Starczewski,
Esq....April 2008
Cash Balance Conversions And Other “Greater of”
Formulas ,
By Carol H. Jewett, Esq. and Felicia A. Finston,
Esq.....April 2008
IRS Announces Opening of Determination Letter Program for
Employers Adopting Pre-Approved Defined Contribution Plans ,
By Kathy Davidson Ireland....April 2008
Claiming a Worthless Stock Deduction May Have Become a Little
Easier ,
By Todd B. Reinstein, Esq.....April 2008
Deductibility of Corporate Trustee Commissions ,
By Sharon L. Klein, Esq.....April 2008
Hybrid Entities and Foreign Tax Reduction ,
By Philip D. Morrison, Esq....March 2008
Economic Stimulus Act Provides Incentives to Businesses and
Refundable Credits to Individuals ,
By Michelle Parten, Esq....March 2008
2007 Technical Correction to §954(c)(6) ,
By Lowell D. Yoder,
Esq....March 2008
NatWest
In Defense of the Qualified Intermediary Program ,
By Edward Tanenbaum,
Esq....March 2008
So the Dog Ate Your S-Corp Election? The IRS Might be Willing to
Throw You a Bone ,
By Craig Pendarvis,
Esq....March 2008
IRS Ruling Creates Uncertainty Regarding What Constitutes
Performance-Based Compensation Under §162(m) ,
By Joseph Adams, Esq., Robert Feldgarden, Esq., Andrew Liazos,
Esq., and Stephen Pavlick,
Esq....March 2008
IRS Issues More §162(m) Guidance ,
By Joseph Adams, Esq., Robert Feldgarden, Esq., Andrew Liazos,
Esq., and Stephen Pavlick,
Esq....March 2008
Where Permissible Issue Advocacy and Prohibited Campaigning
Intersect, Uncertainty Persists ,
By Nina J. Crimm, Professor of
Law...March 2008
To Capitalize or Not to Capitalize--The First Question in the
Amortization Puzzle ,
By Annette Nellen,
Professor...March 2008
Amortization Simplicity Not Obvious for Acquired Domain Names ,
By Annette Nellen,
Professor...March 2008
Closer Look at a Technical Self-Employment Tax Issue ,
By James Edward Maule, Professor of
Law...February 2008
FIRPTA in the 21st Century, Installment Three: FIRPTA and Foreign
PTPs ,
By Kimberly S. Blanchard,
Esq...February 2008
Notice 2008-10: Some Sandwiches Are Tasty and Some Aren't ,
By Kenneth J. Krupsky,
Esq...February 2008
Paying for Education as Part of an Estate Plan: 529 Plans ,
By Elizabeth Carrott Minnigh,
Esq...February 2008
The United Kingdom Floats “Principles-based” Proposals
Attacking Certain Financial Transactions ,
By James J. Tobin,
Esq...February 2008
Further Thoughts on the Proposed Regulations Dealing with Public
Self-Tender Transactions ,
By David R. Tillinghast,
Esq...February 2008
The Muddled State of the TEFRA Partnership Statute of
Limitations ,
By Steven R. Mather,
Esq...February 2008
Third Circuit Weighs in on FICA Status of Severance Payments to
Tenured Faculty ,
By Kathy Davidson Ireland,
Esq...January 2008
Taxpayers Continue to Fight And Continue to Lose in Their Battle
to Deduct AMT Losses From ISOs ,
By Lisa M. Starczewski,
Esq...January 2008
Cash D Reorganizations--Selected International Issues ,
By Lowell D. Yoder,
Esq...January 2008
TE for New Canada-U.S. Protocol Should Eliminate an Old
Uncertainty ,
By Philip D. Morrison,
Esq...January 2008
Who Ate the Homework? The Treasury Department Reports to Congress
on Earnings Stripping, Transfer Pricing, and U.S. Income Tax
Treaties ,
By Willard B. Taylor,
Esq...January 2008
Section 1441 Again: Proposed Regulations on Distributions in
Redemption of Stock ,
By Edward Tanenbaum,
Esq...January 2008
Amortizable §197 Intangibles and Partnerships ,
By James M. Kehl, CPA...December
2007
One More Controversial Corporate Pay-For in H.R. 3970: Deferral of
U.S. Deductions Allocable to CFC Deferred Income ,
By Kenneth J. Krupsky,
Esq....December
2007
Future Relief Under §1031 Possible Upon Bankruptcy of
Qualified Intermediary ,
By David I. Kempler,
Esq....December
2007
IRS Issues Questionnaire on a Transaction of Interest ,
By David I. Kempler,
Esq....December
2007
Proposed Regulations Facilitate Estate Planning For S Corps ,
By Louis A. Mezzullo,
Esq....December
2007
Worker Misclassification, Co-Employment, and the Efficacy of
Assignment Limits--How Not to Solve the “Microsoft”
Problem ,
By Alden J. Bianchi,
Esq....December
2007
Proposed Regulation on the Source of Income of Artists, Athletes,
and Other Performers Raises Many Questions ,
By David R. Tillinghast,
Esq....December
2007
Chairman Rangel Consolidates ,
By James J. Tobin,
Esq....December
2007
FIRPTA in the 21st Century--Installment Two: The 5% Public
Shareholder Exception ,
By Kimberly S. Blanchard,
Esq....December
2007
Durable Powers of Attorney Are Not Simple Forms ,
By Andrew H. Hook,
Esq....December
2007
New Uniform Power of Attorney Act Developed to Address Problem
Areas Associated With Durable Powers of Attorney ,
By Andrew H. Hook,
Esq....December
2007
Age, Sex and Disability Discrimination in Employee Benefit
Plans ,
By William J. Flanagan,
Esq....December
2007
Limited Liability Companies as Exempt Organizations ,
By Bradley T. Borden, Associate Professor of
Law....December
2007
