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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.

Recent Additions
> Gains from the Sale of EU Carbon Emission Allowances Not Treated as Subpart F Income, By David R. Tillinghast, Esq....August 2008
> District Court Clarifies Standard for Providing Notice of Plan Limitations Provisions, By Michael T. Graham and Joanna C. Enstice...August 2008
> Timber Investments for Foreigners and the New Component of Section 631(b), By Professor Richard A. Westin...August 2008
> Inconsistent Application of the Attribution Rule, By Professor Karen B. Brown...August 2008
> Capitalization of Prepaid IDCs: The Government Position on Audit, By Professor Richard A. Westin...August 2008
> Special Allocations of Percentage Depletion, By Professor Richard A. Westin...August 2008
> IRS Rules That Wall Street Cannot Buy Your Company's Pension Plan--Yet, By Michael G. Kushner, Esq....August 2008
> You've Got to Have HEART -- Except for Green Card Holders, By James J. Tobin, Esq....August 2008
> New §956 Regulations: Shoot First, No Comments Later, Please!, By Kenneth J. Krupsky, Esq....August 2008
> FIRPTA in the 21st Century, Installment Five: §897(h)(1) and Tiered REIT Liquidations, By Kimberly S. Blanchard, Esq....August 2008
> Proposed Intercompany Obligations Regulations , By George L. White, Esq....August 2008
> Current Initiatives by IRS to Assist Small Employers that Adopt Pre-Approved Qualified Retirement Plan Documents, By Barry Kozak, Esq....August 2008
> Reporting and Disclosure Issues With Small Employer Employee Benefit Plans, By Barry Kozak, Esq....August 2008
> Valuation of Restricted Management Account Gifts for Gift Tax Purposes, By William P. Streng, Vinson & Elkins Professor of Law...August 2008
> The Fiduciary Corner: Rollovers to Plan Service Providers Present Fiduciary Concerns, By Gregory L. Ash...August 2008
> The F Reorganization -- Too Small to Fail?, By Michael J. Kliegman, Esq....August 2008
> Subpart F: The Proposed Non-Physical Manufacturing Branch, By Lowell D. Yoder, Esq....July 2008
> Finalization of Regs. §1.7874-1T Comes with Additional Warnings, By Edward Tanenbaum, Esq....July 2008
> Final §704(b) Regulations, By Willard B. Taylor, Esq....July 2008
> Is a Disregarded Entity Still a Person (or Even an Entity, for Certain Purposes)?, By Philip D. Morrison, Esq....July 2008
> Challenging an IRS Determination of a Claim for a Whistleblower Award: The Tax Court's Newest Jurisdiction, By Theodore D. Peyser, Esq....July 2008
> Deferred Compensation--Will It Make My Future Sunny? Or Would It Be Better If I Just Take the Money?, By Gerald S. Deutsch, Esq., Attorney at Law and CPA...July 2008
> HEART Act Requires Employers to Provide Benefits to Employees Called to Military Service, By Brian M. Pinheiro, Esq. and Jacquelyn M. Gray, Esq....June 2008
> Year-End Deadline for §403(b) Plans Approaches, By Larry A. Hansen, Esq. and Linda A. Wilkins, Esq....June 2008
> Use of Statistical Techniques to Estimate §458 Adjustments to Income, By Michael H. Salama, Esq....June 2008
> The Tax Court's Surprising About-Face on the Scope of Sanctions Against the IRS for Attorney Misconduct, By Theodore D. Peyser, Esq....June 2008
> Tax Court Makes it More Difficult For Limited Partners/LLC Members to Increase At-Risk Amounts, By Lisa M. Starczewski, Esq....June 2008
> Two New Employer Stock Drop Cases Emphasize Advantage of Proper Plan Language, By Philip J. Weis, Esq....June 2008
> Unrelated Business Activities of Exempt Credit Unions: An Analysis of 2007 TAMs, By Carla Neeley Freitag, Esq....June 2008
> The Proposed Contract Manufacturing Regulations: A Journey of a Thousand Miles Begins With a Single Step, By James J. Tobin, Esq....June 2008
> Prevost Car v. The Queen: Who is the Beneficial Owner of Dividends--in Canada, in the Netherlands, in the United States?, By Kenneth J. Krupsky, Esq....June 2008
> IRS Announces Development of Procedures for Implementing Arbitration under the Protocol with Germany, By David R. Tillinghast, Esq....June 2008
> FIRPTA in the 21st Century, Installment Four: FIRPTA Withholding Mechanics, By Kimberly S. Blanchard, Esq....June 2008
> A Bonus In Stock-and I'm the One You Choose? Don't Be Upset But I'd Like to Refuse, By Gerald S. Deutsch, Esq....June 2008
> Estate of Mirowski v. Commissioner, By Louis A. Mezzullo, Esq....June 2008
> Get Ready for the New Form 990, By Lisa B. Petkun, Esq....May 2008
> Dealing on a Global Basis with Transfer Pricing Documentation Requirements, By Marc M. Levey, Esq....May 2008
> Foreign Investment in Regulated Investment Companies, By Willard B. Taylor, Esq....May 2008
> Subpart F Manufacturing Exception: Proposed Non-Physical Definition of Manufacturing, By Lowell D. Yoder, Esq....May 2008
> The Atomic Theory of Subpart F, By Philip D. Morrison, Esq....May 2008
> 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, By Edward Tanenbaum, Esq....April 2008
> 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 Case, By Willard B. Taylor, Esq....March 2008
> 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