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.
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Gains from the Sale of EU Carbon Emission Allowances Not Treated
as Subpart F Income,
By David R. Tillinghast,
Esq....August 2008 |
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District Court Clarifies Standard for Providing Notice of Plan
Limitations Provisions,
By Michael T. Graham and Joanna C.
Enstice...August 2008 |
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Timber Investments for Foreigners and the New Component of Section
631(b),
By Professor Richard A.
Westin...August 2008 |
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Inconsistent Application of the Attribution Rule,
By Professor Karen B. Brown...August 2008 |
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Capitalization of Prepaid IDCs: The Government Position on
Audit,
By Professor Richard A.
Westin...August 2008 |
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Special Allocations of Percentage Depletion,
By Professor Richard A.
Westin...August 2008 |
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IRS Rules That Wall Street Cannot Buy Your Company's Pension
Plan--Yet,
By Michael G. Kushner, Esq....August 2008 |
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You've Got to Have HEART -- Except for Green Card Holders,
By James J. Tobin, Esq....August 2008 |
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New §956 Regulations: Shoot First, No Comments Later,
Please!,
By Kenneth J. Krupsky, Esq....August 2008 |
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FIRPTA in the 21st Century, Installment Five: §897(h)(1) and
Tiered REIT Liquidations,
By Kimberly S. Blanchard, Esq....August 2008 |
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Proposed Intercompany Obligations Regulations ,
By George L. White, Esq....August 2008 |
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Current Initiatives by IRS to Assist Small Employers that Adopt
Pre-Approved Qualified Retirement Plan Documents,
By Barry Kozak, Esq....August 2008 |
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Reporting and Disclosure Issues With Small Employer Employee
Benefit Plans,
By Barry Kozak, Esq....August 2008 |
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Valuation of Restricted Management Account Gifts for Gift Tax
Purposes,
By William P. Streng, Vinson & Elkins Professor of
Law...August 2008 |
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The Fiduciary Corner: Rollovers to Plan Service Providers Present
Fiduciary Concerns,
By Gregory L. Ash...August 2008 |
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The F Reorganization -- Too Small to Fail?,
By Michael J. Kliegman,
Esq....August 2008 |
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Subpart F: The Proposed Non-Physical Manufacturing Branch,
By Lowell D. Yoder,
Esq....July 2008 |
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Finalization of Regs. §1.7874-1T Comes with Additional
Warnings,
By Edward Tanenbaum,
Esq....July 2008 |
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Final §704(b) Regulations,
By Willard B. Taylor,
Esq....July 2008 |
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Is a Disregarded Entity Still a Person (or Even an Entity, for
Certain Purposes)?,
By Philip D. Morrison,
Esq....July 2008 |
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Challenging an IRS Determination of a Claim for a Whistleblower
Award: The Tax Court's Newest Jurisdiction,
By Theodore D. Peyser,
Esq....July 2008 |
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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 |
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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 |
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Year-End Deadline for §403(b) Plans Approaches,
By Larry A. Hansen, Esq. and Linda A. Wilkins,
Esq....June 2008 |
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Use of Statistical Techniques to Estimate §458 Adjustments to
Income,
By Michael H. Salama,
Esq....June 2008 |
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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 |
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Tax Court Makes it More Difficult For Limited Partners/LLC Members
to Increase At-Risk Amounts,
By Lisa M. Starczewski,
Esq....June 2008 |
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Two New Employer Stock Drop Cases Emphasize Advantage of Proper
Plan Language,
By Philip J. Weis,
Esq....June 2008 |
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Unrelated Business Activities of Exempt Credit Unions: An Analysis
of 2007 TAMs,
By Carla Neeley Freitag,
Esq....June 2008 |
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The Proposed Contract Manufacturing Regulations: A Journey of a
Thousand Miles Begins With a Single Step,
By James J. Tobin,
Esq....June 2008 |
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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 |
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IRS Announces Development of Procedures for Implementing
Arbitration under the Protocol with Germany,
By David R. Tillinghast,
Esq....June 2008 |
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FIRPTA in the 21st Century, Installment Four: FIRPTA Withholding
Mechanics,
By Kimberly S. Blanchard,
Esq....June 2008 |
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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 |
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Estate of Mirowski v. Commissioner,
By Louis A. Mezzullo, Esq....June 2008 |
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Get Ready for the New Form 990,
By Lisa B. Petkun, Esq....May 2008 |
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Dealing on a Global Basis with Transfer Pricing Documentation
Requirements,
By Marc M. Levey, Esq....May 2008 |
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Foreign Investment in Regulated Investment Companies,
By Willard B. Taylor, Esq....May 2008 |
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Subpart F Manufacturing Exception: Proposed Non-Physical
Definition of Manufacturing,
By Lowell D. Yoder, Esq....May 2008 |
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The Atomic Theory of Subpart F,
By Philip D. Morrison, Esq....May 2008 |
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Release of Form 990 Draft Instructions,
By Elizabeth Carrott Minnigh, Esq....May 2008 |
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Section 403(b) Plans for Tax-Exempt Employers--the Collective
Bargaining Dilemma,
By Carol H. Jewett, Esq. and Felicia A. Finston, Esq....April 2008 |
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IRS Agents Reprimanded,
By Nicholas S. Curabba, Esq....April 2008 |
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Should a Nonresident Alien Make a §83(b) Election? (And Some
More Musings on FIRPTA),
By Kimberly S. Blanchard, Esq....April 2008 |
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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 |
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Proposed Contract Manufacturing Regulations and Pablo Picasso,
By Kenneth J. Krupsky,
Esq....April 2008 |
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Swallows Revisited,
By Edward Tanenbaum,
Esq....April 2008 |
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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 |
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The AMT and Stock Options: Taxpayers Continue to Lose in the
Appellate Courts,
By Lisa M. Starczewski,
Esq....April 2008 |
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Cash Balance Conversions And Other “Greater of”
Formulas,
By Carol H. Jewett, Esq. and Felicia A. Finston,
Esq.....April 2008 |
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IRS Announces Opening of Determination Letter Program for
Employers Adopting Pre-Approved Defined Contribution Plans,
By Kathy Davidson Ireland....April 2008 |
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Claiming a Worthless Stock Deduction May Have Become a Little
Easier,
By Todd B. Reinstein, Esq.....April 2008 |
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Deductibility of Corporate Trustee Commissions,
By Sharon L. Klein, Esq.....April 2008 |
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Hybrid Entities and Foreign Tax Reduction,
By Philip D. Morrison, Esq....March 2008 |
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Economic Stimulus Act Provides Incentives to Businesses and
Refundable Credits to Individuals,
By Michelle Parten, Esq....March 2008 |
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2007 Technical Correction to §954(c)(6),
By Lowell D. Yoder,
Esq....March 2008 |
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NatWest Case,
By Willard B. Taylor,
Esq....March 2008 |
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In Defense of the Qualified Intermediary Program,
By Edward Tanenbaum,
Esq....March 2008 |
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So the Dog Ate Your S-Corp Election? The IRS Might be Willing to
Throw You a Bone,
By Craig Pendarvis,
Esq....March 2008 |
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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 |
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IRS Issues More §162(m) Guidance,
By Joseph Adams, Esq., Robert Feldgarden, Esq., Andrew Liazos,
Esq., and Stephen Pavlick,
Esq....March 2008 |
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Where Permissible Issue Advocacy and Prohibited Campaigning
Intersect, Uncertainty Persists,
By Nina J. Crimm, Professor of
Law...March 2008 |
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To Capitalize or Not to Capitalize--The First Question in the
Amortization Puzzle,
By Annette Nellen,
Professor...March 2008 |
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Amortization Simplicity Not Obvious for Acquired Domain Names,
By Annette Nellen,
Professor...March 2008 |
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Closer Look at a Technical Self-Employment Tax Issue,
By James Edward Maule, Professor of
Law...February 2008 |
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FIRPTA in the 21st Century, Installment Three: FIRPTA and Foreign
PTPs,
By Kimberly S. Blanchard,
Esq...February 2008 |
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Notice 2008-10: Some Sandwiches Are Tasty and Some Aren't,
By Kenneth J. Krupsky,
Esq...February 2008 |
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Paying for Education as Part of an Estate Plan: 529 Plans,
By Elizabeth Carrott Minnigh,
Esq...February 2008 |
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The United Kingdom Floats “Principles-based” Proposals
Attacking Certain Financial Transactions,
By James J. Tobin,
Esq...February 2008 |
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Further Thoughts on the Proposed Regulations Dealing with Public
Self-Tender Transactions,
By David R. Tillinghast,
Esq...February 2008 |
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The Muddled State of the TEFRA Partnership Statute of
Limitations,
By Steven R. Mather,
Esq...February 2008 |
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Third Circuit Weighs in on FICA Status of Severance Payments to
Tenured Faculty,
By Kathy Davidson Ireland,
Esq...January 2008 |
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Taxpayers Continue to Fight And Continue to Lose in Their Battle
to Deduct AMT Losses From ISOs,
By Lisa M. Starczewski,
Esq...January 2008 |
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Cash D Reorganizations--Selected International Issues,
By Lowell D. Yoder,
Esq...January 2008 |
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TE for New Canada-U.S. Protocol Should Eliminate an Old
Uncertainty,
By Philip D. Morrison,
Esq...January 2008 |
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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 |
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Section 1441 Again: Proposed Regulations on Distributions in
Redemption of Stock,
By Edward Tanenbaum,
Esq...January 2008 |
