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By Practice Area: Tax Controversies

Alerts

Tax Alert
IRS Kicks Off Post-Altera Audit Adjustments
September 21, 2020
Tax Alert
The IRS Resumes its Global High-Wealth Examination Program and Targets High Income Non-Filers
July 22, 2020
Tax Alert
Challenge to the Constitutionality of the ACA Raises NII Tax Refund Possibility
July 6, 2020
Tax Alert
IRS Will Continue Captive Insurance and Syndicated Conservation Easement Examinations Despite Covid-19 Pandemic
April 27, 2020
Tax Alert
Damage Mitigation: The IRS Helps Alleviate Effect of COVID-19 on U.S. and Foreign Residency
April 22, 2020
Tax Alert
Partnership Filing Relief
April 13, 2020
Tax Alert
Updated Filing and Payment Extensions Under Notice 2020-23
April 10, 2020
Tax Alert
Collateral Damage: Covid-19 and its Unintended Effect on U.S. Residency
April 1, 2020
Tax Alert
Captive Soft Letter
March 31, 2020
Tax Alert
Abatement of Foreign Pension Trust Penalties
March 31, 2020
Tax Alert
The Impact of Notice 2020-18 on Information Returns
March 30, 2020
Tax Alert
IRS Announces Tax Collection Easing and Payment Flexibility During COVID-19 Crisis
March 30, 2020
Tax Alert
CARES Act Offers Income Tax Relief for Business
March 27, 2020
Tax Alert
New Cryptocurrency Guidance
October 22, 2019
Tax Alert
Cryptocurrency Criminal Tax Cases Coming Soon
July 23, 2019
Tax Alert
Tax Problems Loom in the College Admissions Scandal
March 18, 2019
Tax Alert
The New Voluntary Disclosure Practice: A Fair Compromise?
December 3, 2018
Tax Alert
Year-End Updates on Partnership Representatives
November 6, 2018
Tax Alert
IRS Adds Foreign Trust Information Reporting to Compliance Campaign Program
June 1, 2018
Tax Alert
IRS's Offshore Voluntary Disclosure Program Ending: Impact on U.S. Taxpayers
March 14, 2018
Tax Alert
IRS to Revoke Passports for Seriously Delinquent Tax Debts Starting February 2018
February 12, 2018
Tax Alert
New Partnership Audit Rules Go Live
January 9, 2018
Tax Alert
Tax Reform May Make Payment of Nonbusiness Tax Advice Fees Non-Deductible
December 12, 2017
Tax Alert
Possible Tax Fallout for Student and Professional Athletes from NCAA-Related Investigations
November 9, 2017
Tax Alert
Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets
November 6, 2017
International Tax Alert
Different Viewpoint Not a Misrepresentation: Tax Court Holds IRS Abused Its Discretion in Cancelling Eaton's APAs
August 24, 2017
Tax Alert
Captive Insurance Industry Should Be Aware of State Reporting Obligations for Transactions of Interest
February 10, 2017
Tax Alert
IRS Launches 13 Issue-Based Corporate Compliance Campaigns
February 3, 2017
Tax Alert
Syndicated Conservation Easement Transactions Identified as New "Listed Transactions"
January 3, 2017
International Tax Alert
Treasury Issues Final Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership
December 19, 2016
Tax Alert
Congress Looks to Fix New Partnership Audit Rules
December 14, 2016
Tax Alert
Voluntary Disclosure Window Closing on Bitcoin Users
December 2, 2016
Tax Alert
Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations
November 3, 2016
Tax Alert
IRS Issues First Partnership Audit Regulations
August 8, 2016
Tax Alert
The Panama Papers and the U.S. Response: New Risks for Financial Institutions, Clients and Advisors
May 18, 2016
Tax Alert
IRS to Hire 700 for Civil and Criminal Tax Enforcement
May 5, 2016
Tax Alert
Treasury Announces Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership
April 5, 2016
Tax Alert
IRS Seeks Comments to Promulgate Regulations for New Tax Examination and Collection Regime for Partnerships and LLCs
March 18, 2016
Tax Alert
IRS/DOJ Summons Seeks to Break Singapore Bank Secrecy on Non-Resident's Account
March 7, 2016
Tax Alert
Congress Enacts Entirely New Tax Examination and Collection Regime for Partnerships
December 10, 2015
Tax Alert
U.S. Passports in Jeopardy for Taxpayers Owing the IRS
December 9, 2015
Private Client Alert
Steps Foreign Persons Can Take to Avoid Unnecessary U.S. Estate Tax
November 9, 2015
Tax Alert
New Law Changes FBAR Filing Deadline
August 10, 2015
International Tax Alert
IRS Releases Guidelines for Examining CFC Transactions
July 29, 2015
International Tax Alert
Treasury Proposes Significant Changes to U.S. Model Tax Treaty
May 26, 2015
Tax Alert
Abusive Small Captive Insurance Companies Added to IRS "Dirty Dozen Tax Scams"
February 13, 2015
Business, Investment & Transactional Tax Alert
NYC Proposed Tax Code Changes Would Affect Businesses Large and Small
January 13, 2015
Tax Alert
Switzerland Narrows Advance Notice to Account Holders of Treaty Requests: Americans with Unreported Accounts Impacted
December 16, 2014
International Tax Alert
OECD Releases Finalized Proposals on Key Tax Base Erosion Concerns
September 23, 2014
Tax Alert
IRS Issues Final Regulations on Material Advisor Penalties
August 4, 2014
Tax Alert
IRS Modifies Offshore Voluntary Disclosure Program and Streamlined Filing Compliance Procedures
June 23, 2014
International Tax Alert
Remain Vigilant on Indian Permanent Establishments, Even After the Favorable e-Funds Decision
March 27, 2014
International Tax Alert
Bold Shift in IRS Approach to Transfer Pricing Controversies
February 27, 2014
Tax Alert
DOJ Deal with Swiss Banks Impacts U.S. Taxpayers and Financial Firms Around the World
October 31, 2013
Exempt Organizations Alert
Washington Post Releases Database of Reported Nonprofit Asset Diversions
October 30, 2013
Exempt Organizations Alert
Stalled Applications for Section 501(c)(3) Status: Is it Time to Sue the IRS?
August 16, 2013
Business, Investment & Transactional Tax Alert
Global Netting: Potential Opportunities for Corporate Taxpayers
April 10, 2013
International Tax Alert
Professional Golfer Sergio Garcia to Owe More Taxes on Endorsement Income
March 15, 2013
Private Client Alert
Federal Judge Grants IRS "John Doe" Summons Seeking California Gift Tax Records
December 22, 2011
Tax Alert
LB&I Commissioner Provides Guidance to Examiners and Managers on the Codified Economic Substance Doctrine and Related Penalties
July 29, 2011
International Tax Alert
More Foreign Financial Account Reporting
March 26, 2010
International Tax Alert
Looking for FBARs in All the Wrong Places? Limited Relief in New Interim Guidance
March 15, 2010
Employee Benefits Alert
Get Ready for the Employment Tax Compliance Surge: IRS to Challenge Status of Independent Contractors
February 18, 2010

Published Articles & Books

BLOG: Centralized Partnership Audit Regime Website Launched by IRS
www.PartnershipRepresentative.com
September 8, 2020
TAX PRACTICE: A Silver Linings Guidebook: Corporate Planning for Coronavirus Losses
Tax Notes Federal
May 18, 2020
INSIGHT: The IRS's Renewed Focus on Fraud-Implications for Tax Practitioners
Bloomberg Law
May 8, 2020
BLOG: IRS Issues LB&I Memorandum
www.PartnershipRepresentative.com
April 7, 2020
BLOG: IRS Release Clarifications for Form 8082
www.PartnershipRepresentative.com
March 19, 2020
BLOG: IRS Release Draft Instructions to Form 8978
www.PartnershipRepresentative.com
February 26, 2020
Interpreting the TCJA: Standing Up (With Reservations) for Treasury
Tax Notes Federal Letters to the Editor
January 27, 2020
BLOG: IRS Releases Interim Guidance Centralized Partnership Audit Regime
www.PartnershipRepresentative.com
November 27, 2019
BLOG: IRS Releases Interim Guidance on BBA Partnership Audit Procedures
www.PartnershipRepresentative.com
October 24, 2019
Sharia Law Is Already Here - The IRS Must Respond
The Hill Op-Ed
October 18, 2019
Financier Worldwide Annual Review: Transfer Pricing 2019 – United States
Financier Worldwide
October 7, 2019
COMMENTARY & ANALYSIS: The TCJA and the Treaties
Tax Notes International Magazine
September 9, 2019
Decrypting The New IRS Cryptocurrency Compliance Letters
Law360 Tax Authority
August 7, 2019
BLOG: Remember That You Must Appoint a Partnership Representative with Extended Form 1065 for the 2018 Tax Year
www.PartnershipRepresentative.com
July 25, 2019
Combating Aggressive Tax Planning Through Disclosure: A Comparison of U.S. and EU Rules Applicable to Tax Advisors
ABA Tax Times
June 14, 2019
Deductibility of Illegal Payments, Fines, and Penalties (Book)
Bloomberg Tax 524-2nd Tax Management Portfolio
May 3, 2019
BLOG: IRS Publishes New Form 8981 and Form 8984
www.PartnershipRepresentative.com
March 19, 2019
Deal or No Deal: The Unknown Cost of the IRS's New Voluntary Disclosure Practice
White Collar Crime Committee Newsletter
February 28, 2019
EXPERT ANALYSIS: Planning For Partnership Representatives In The New Year
Law360
January 4, 2019
BLOG: Tax Court Rules - Partnership Representative
www.PartnershipRepresentative.com
December 28, 2018
BLOG: IRS Publishes Draft Instructions for Form 8979, Partnership Representative Revocation, Designation, and Resignation Form
www.PartnershipRepresentative.com
December 5, 2018
Navigating QBAI Quirks of the GILTI Regulations
Bloomberg Tax, Tax Management International Journal
November 5, 2018
COMMENTARY & ANALYSIS: The BEAT and the Treaties
Tax Notes International Magazine
October 15, 2018
INSIGHT: People, Places, and Things: Final Regulations on the Eligibility, Designation, Revocation, and Authority of Partnership Representatives
Bloomberg Tax: Daily Tax Report
September 11, 2018
Kumquat: The U.S. International Tax Issues
Tax Notes International Magazine
June 25, 2018
EXPERT ANALYSIS: U.S. Owners of Foreign Trusts Face Increased IRS Scrutiny
Law360
June 21, 2018
Mining for Meaning: An Examination of the Legality of Property Rights in Space Resources
Virginia Law Review
May 1, 2018
INSIGHT: Last Call for OVDP: Use It or Lose It
Bloomberg Tax: Daily Tax Report
April 20, 2018
Chapter 9: Filing Claims and Suits for Refund of Overpayments
American Bar Association
April 9, 2018
INSIGHT: BEAT Strikes the Wrong Note
Bloomberg Tax: Daily Tax Report
March 16, 2018
INSIGHT: First Class, Global Entry, and Now Tax Compliance: the New Must-Have for Today's International Traveler
Bloomberg Tax: Daily Tax Report
March 6, 2018
GILTI Pleasures
Tax Notes International Magazine
February 12, 2018
United Nations Handbook on Selected Issues in Protecting the Tax Base of Developing Countries - Chapter IV: Limiting Interest Deductions
United Nations
January 22, 2018
U.S. Plays Lone Ranger on International Tax to Its Detriment
The Hill Op-Ed
January 19, 2018
International Aspects of U.S. 'Tax Reform' -- Is This Really Where We Want to Go?
International Tax Report
January 2, 2018
David Rosenbloom Comments on Tax Bills' Impact on Earnings of U.S.-Owned Foreign Corporations
The Washington Post Op-Ed
December 3, 2017
Low-Tax Texas Should Pay Its Fair Share of Harvey Costs
The Washington Post Op-Ed
September 6, 2017
Foreword for Asian Voices: BEPS and Beyond
International Bureau of Fiscal Documentation (IBFD)
July 1, 2017
Sexton Opinion Further Restricts What Conduct Can Be Regulated Under "Practice" Before the IRS
ABA Tax Times
June 1, 2017
U.S. Corporate Tax Reform and Wallace Stevens
Tax Notes
May 30, 2017
The Destination-Based Cash Flow Tax Is a VAT?
Tax Notes
March 29, 2017
Transfer Pricing Forum
Bloomberg BNA
March 17, 2017
Captive Insurance: State Reporting Obligations for Transactions of Interest
International Law Office
March 3, 2017
U.S. Corporate Tax Reform and Jean-Paul Sartre
Tax Notes
March 1, 2017
IRS Launches Issue-Based Corporate Compliance Campaigns
International Law Office
February 24, 2017
Where Have All the Transfer Pricing Safe Harbors Gone? A Plea for Reinvigoration
Bloomberg BNA, Tax Management Transfer Pricing Report
February 23, 2017
Will Border Adjustment Tax End Transfer Pricing as We Know It?
Bloomberg BNA, Tax Management Transfer Pricing Report
February 23, 2017
IRS Launches Issue Based Corporate Compliance Campaigns
Global Tax Weekly
February 16, 2017
Reconsidering European Court of Justice Jurisprudence on Limitation on Benefits Clauses: Why the U.S. Should Care
46 TM Int'l J. 83, Bloomberg BNA Tax Management International Journal
February 10, 2017
Syndicated Conservation Easement Transactions Identified as New 'Listed Transactions'
International Law Office
January 27, 2017
The U.S. Must Avoid This Untested Approach To International Taxes
The Hill Op-Ed
January 24, 2017
The New Partnership Audit Regime: What We Know, What We Do Not and What Is Next
Tax Management Memorandum, Bloomberg BNA
January 23, 2017
Treasury Issues Regulations Addressing Use of LLCs to Disguise Beneficial Ownership
International Law Office
January 20, 2017
Tax Claims - Court of Federal Claims: Jurisdiction, Practice, and Procedure
Court of Federal Claims: Jurisdiction, Practice, and Procedure
January 9, 2017
Congress Looks to Fix New Partnership Audit Rules
International Law Office
January 6, 2017
Tax Plans Compared (December 2016) Corporate Tax
Global Tax Weekly
January 5, 2017
Voluntary Disclosure Window Closing for Bitcoin
International Law Office
December 16, 2016
Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations
International Law Office
November 25, 2016
Financier Worldwide Annual Review: Transfer Pricing 2016 – United States
Financier Worldwide
November 16, 2016
New Regulations Change Allocation of Partnership Liabilities
International Law Office
November 4, 2016
New Regulations Change Allocation of Partnership Liabilities
Global Tax Weekly
November 3, 2016
U.S. Tax Enforcers React to The Panama Papers
IFC Review
September 1, 2016
Is the United States Still a Tax Haven? The Government Acts on Tax Compliance and Money Laundering Risks
CCH's Journal of Tax Practice & Procedure
July 25, 2016
Report of Foreign Bank and Financial Accounts (FBAR) (Book)
Bloomberg BNA's Tax Management Portfolio
June 29, 2016
IRS to Hire 700 for Civil and Criminal Tax Enforcement
International Law Office
May 20, 2016
IRS Seeks Comments for New Tax Examination and Collection Regime
International Law Office
April 8, 2016
US Congress Enacts Entirely New Tax Examination and Collection Regime for Partnerships and LLCs
Family Office Elite Magazine
April 1, 2016
IRS Criminal Investigation: A National Asset Being Damaged
Tax Notes
March 14, 2016
2016 Federal Tax Benefits for Hiring Qualified Veterans, National Guard Members and Reservists (Book)
Caplin & Drysdale, Chartered
March 1, 2016
Derivative Benefits and Equivalent Beneficiaries - What Are We Talking About? Part II
International Tax Report
December 10, 2015
Derivative Benefits and Equivalent Beneficiaries - What Are We Talking About? Part I
International Tax Report
November 5, 2015
‘Just Add SaLT!' When and How to Consider State Tax Ethical Issues in Advising Clients
ABA Tax Times
October 30, 2015
Transfer Pricing Audits: Flipping the Tested Party
International Law Office
August 28, 2015
Applying Tobacco Tax Lessons to Sugary Drinks
University of Pennsylvania Law School, The Regulatory Review
August 27, 2015
IRS Releases Guidelines for Examining CFC Transactions
International Law Office
August 21, 2015
The Tax Planner's Tightrope: Morality and Politics Now in Play
International Law Office
August 14, 2015
The Need for Federal Oversight of Tax Preparers
University of Pennsylvania Law School, The Regulatory Review
August 10, 2015
The Practical Protection of Taxpayers' Fundamental Rights
International Fiscal Association 2015 Basel Congress
August 1, 2015
The Intersection of U.S. Tax Treaty Policy, Tax Reform, and BEPS
International Law Office
July 24, 2015
Moore Requires 'More' Scrutiny of IRS-Imposed FBAR Penalties Under the Administrative Procedures Act
Family Office Elite Magazine
July 17, 2015
FATCA – Enforcement Win or Expatriate Generator?
IFC Review
July 1, 2015
Treasury Proposes Significant Changes to Model Tax Treaty
International Law Office
June 12, 2015
Treasury Proposes Significant Changes to U.S. Model Treaty
Global Tax Weekly
June 4, 2015
Reflections on the Intersection of U.S. Tax Treaty Policy, U.S. Tax Reform, and BEPS
Tax Notes International
May 25, 2015
The Tax Planner's Tightrope: Morality and Politics Now in Play
IFC Economic Report
May 5, 2015
Abusive Small Captive Insurance Companies on IRS 'Dirty Dozen' List
International Law Office
February 27, 2015
Filing Claims and Suits for Refund Overpayments
American Bar Association, Section of Taxation
February 25, 2015
Proposed New York Tax Changes Would Affect Large and Small Businesses
International Law Office
January 30, 2015
Will the Rush to Invert Spur Corporate Tax Reform? A Conversation
Tax Notes International
December 15, 2014
The Current State of Expatriation
ALI CLE Estate Planning Course Materials Journal
December 1, 2014
IRS May Restrict Informal Refund Claims for LB&I Taxpayers Under Exam
Procedurally Taxing
November 26, 2014
IRS Power To Regulate Tax Practitioners Slipping Away
Forbes
November 10, 2014
OECD Releases Finalized Proposals on Key Tax Base Erosion Concerns
Global Tax Weekly
November 6, 2014
U.S. Offshore Account Enforcement Issues
CCH's Journal of Tax Practice & Procedure
September 30, 2014
IRS Issues Final Regulations On Material Advisor Penalties
Global Tax Weekly
September 4, 2014
Recent Changes in Circular 230: Where Are We Now?
Real Estate Journal
September 3, 2014
IRS Issues Final Regulations on Material Adviser Penalties
International Law Office
August 29, 2014
Remain Vigilant On Indian Permanent Establishments, Even After the Favorable e-Funds Decision
Global Tax Weekly
July 10, 2014
OECD's Proposed New Approach to Transfer Pricing of Intangibles: A Critique
New York University
June 29, 2014
Strategies for Current Filings of Noncompliant Taxpayers as FBAR Deadline Approaches
Practical Tax Strategies
May 23, 2014
Here Comes FATCA…What To Expect In 2014
IFC Review Monthly e-Journal
April 1, 2014
The New APMA Procedures — Cosmetic or Cosmic?
Tax Management International Journal
March 14, 2014
Enforcing Non-U.S. Tax Authority Requests for Taxpayer Information
International Law Office
March 7, 2014
Surprise! Your Foreign Tax Credit Is Not Allowed Under Section 901(I)
Tax Notes International
January 14, 2014
Washington Tax Roundup
Washington Jewish Week
January 8, 2014
A New Tax-and-Spend Strategy to Fight Obesity
University of Pennsylvania Law School, The Regulatory Review
January 6, 2014
Here Comes FATCA…What to Expect in 2014
IFC Review
January 4, 2014
Weighing Fiduciary Duties with 21st Century Realities – Evaluating the Viability of Remote Participation for Boards of Directors
1 Emory Corp. Governance & Accountability Rev. 43
January 1, 2014
The Current State of Expatriation
A Guide to International Estate Planning, American Bar Association, 2nd Ed.
December 31, 2013
FATCA: An Overview of Its Scope and Application to Non-U.S. Entities Chapter
The International Comparative Legal Guide to: Private Client 2014, 3rd Edition
December 23, 2013
Jurisdictional Uncertainty in Trust Fund Recovery Penalty Cases
Tax Notes, p. 963
December 16, 2013
Overview of the OECD'S Action Plan on Base Erosion and Profit Shifting
Corporate Taxation
November 1, 2013
The Justice Department and Swiss Banks: Understanding the Special Disclosure Program
Bloomberg BNA
September 24, 2013
Tax Implications of Natural Disasters
ABA Section of Taxation and Section of Real Property, Trust & Estate Division
September 1, 2013
Me, Myself, and My Subsidiary: A Shift in the Intent Standard in Related-Party Hybrid Debt Cases
Corporate Taxation
September 1, 2013
Amazon.com v. Commissioner: Veritas Redux?
Corporate Taxation
August 1, 2013
Here Are the Implications of Singapore's Move to FATCA Compliance
Singapore Business Review
July 29, 2013
The Crucial Implications of FATCA for U.S. Citizens in Hong Kong
Hong Kong Business
July 25, 2013
FATCA Reporting – Are Trusts and Trustees Caught in the Net?
Financier Worldwide
July 1, 2013
2013 Federal Tax Benefits for Hiring Qualified Veterans, National Guard Members and Reservists (Book)
Caplin & Drysdale, Chartered
June 3, 2013
Low-Income Students Must Aim High, Seize Opportunities Offered to Them
Detroit Free Press
May 7, 2013
Global Netting: Potential Opportunities for Corporate Taxpayers
WTE Practical International Tax Strategies, Volume 17, Number 8
April 30, 2013
The Rescission Decision
Tax Talk, Section of Taxation, Maryland State Bar Association
March 1, 2013
Cruising Toward Safe Harbors for Transfer Pricing?
Corporate Taxation
March 1, 2013
Mutual Administrative Assistance in Tax Matters
Journal of Corporate Taxation
March 1, 2013
Recent Developments: U.K. Excess Profits Tax Under the U.S. Foreign Tax Credit
Corporate Taxation
January 1, 2013
Transfer Pricing: Rules and Practice in Selected Countries (H-1), No. 6955
Bloomberg BNA Tax Management Portfolio
January 1, 2013
FATCA: A New Era of Financial Transparency
AICPA's Journal of Accountancy
January 1, 2013
A Deeper Democracy Begins with Proper Elections: Citizens United, the Rise of the Super PAC and the Loss of Electoral Integrity in the US
University of Oxford and University of Cambridge
December 20, 2012
The Nuts And Bolts of Deficiency Cases: From Examination to The Tax Court
The Practical Tax Lawyer
December 1, 2012
Safe at Last? Transfer Pricing Safe Harbors on the Horizon
Bloomberg BNA
September 6, 2012
Is the Limited Scope Marketed Opinion Preparing for a Comeback?
Tax Talk, Section of Taxation, Maryland State Bar Association
September 1, 2012
Article from Tax Analysts, Switzerland and the U.S.: What We Have Here is a Failure to Communicate
Tax Analysts, by H. David Rosenbloom
June 4, 2012
Offshore Tax Evasion: US Initiatives
Practical Law Company
April 26, 2012
Case Updates-Dell Products (Norway) General Electric Capital (Canada) SNF (Australia)
Corporate Taxation
March 1, 2012
ABA Section of Taxation Comments on Proposed Amendments to the Rules of the United States Tax Court
American Bar Association
March 1, 2012
Protecting Yourself and Your Client in a Joint Defense Arrangement
ABA Section of Taxation News Quarterly
February 1, 2012
Commissionaire and Contract Manufacturing Arrangements - New Developments on Permanent Establishment Issue
Corporate Taxation
January 1, 2012
Offshore Tax Enforcement, Voluntary Disclosure, And Undeclared Foreign Accounts
ALI-ABA Estate Planning Course Materials Journal
December 1, 2011
The APA Program's Experience With Rev. Proc. 2008-31: Increased Opportunities for Certainty
Bloomberg BNA Tax Management Memorandum
November 7, 2011
The Case for Tradable Tax Credits
8 N.Y.U. J.L. & BUS. 227
November 1, 2011
2010 Treaty Developments
Corporate Taxation
November 1, 2011
OVDI Is Over — What's Next for Voluntary Disclosures?
Tax Notes, Special Report
October 17, 2011
Qualified Intermediaries, The EU Savings Directive, Trace--What Does FATCA Really Add
Corporate Taxation
September 1, 2011
Business, Values, and Law: Forging a New Dialogue
Georgetown University, Berkley Center for Religion, Peace & World Affairs
August 30, 2011
Unreported Gifts of Real Property: Time for a Voluntary Disclosure?
Tax Notes
August 1, 2011
India's Proposed Direct Taxes Code - Highlights For Corporate Taxpayers
Corporate Taxation
July 1, 2011
Crawford's Last Stand? What Melendez-Diaz v. Massachusetts Means for the Confrontation Clause and for Criminal Trials
2 AKRON J. CONST. L. & POL'Y 81
June 2, 2011
FATCA & Foreign Bank Accounts: Has the U.S. Overreacted?
Tax Analysts
May 31, 2011
Final Rules & New FBAR Form Issued
International Tax Review
May 1, 2011
ITPF - Georgetown University Law Center Conference on Reform of International Tax
Corporate Taxation
May 1, 2011
IRS Seeks Names of U.S. Account Holders at HSBC (India)
Taxmann-The Tax & Corporate laws of India-International Tax
April 18, 2011
Comments to the Proposed Amendments to the Rules of the United States Tax Court
American Bar Association
March 7, 2011
Comments to the Proposed Amendments to the Rules of the United States Tax Court
American Bar Association
March 7, 2011
Putting an End to Foreign Tax Credit 'Splitting' Transactions
Corporate Taxation
March 1, 2011
ABA Section of Taxation Comments on Proposed Amendments to the Rules of the United States Tax Court
American Bar Association
March 1, 2011
Indictment of Offshore Account Holder Portends a New Round of Aggressive Enforcement
International Taxation
February 1, 2011
Effectively Representing Your Client Before the IRS
American Bar Association
January 3, 2011
U.S. Federal Tax Research
Tax Management Portfolio Series
January 3, 2011
Responsible Person and Lender Liability for Trust Fund Taxes – Sections 6672 and 3505
Tax Management Portfolio Series
January 3, 2011
President Obama's Efforts at International Tax Reform
Corporate Taxation
January 1, 2011
The Foreign Account Tax Compliance Act and Notice 2010-60
International Taxation
December 1, 2010
IRS's Voluntary Disclosure Program for Offshore Accounts: A Critical Assessment After One Year
BNA Insights
September 21, 2010
Advise Client Companies to Review Payroll Practices
Verizon Small Business Center's News & Resources
September 10, 2010
Federal and State Governments Target Employment Tax Compliance
Taxation of Exempts
September 1, 2010
A Shift Toward Consumption Taxes: The Tax Policy Prescription For The Fiscal Ills of The Global Financial Crisis
Corporate Taxation
July 1, 2010
Once Again Employment Tax Compliance at the Forefront of IRS's Enforcement Agenda
Bloomberg Law Reports
June 21, 2010
The Foreign Account Tax Compliance Act
May 11, 2010
Loan Guarantees and Transfer Pricing
Corporate Taxation
May 1, 2010
IRS Scrutinizes Payroll Practices, Challenges for Companies
Financial Executive
May 1, 2010
When Diversity Meets the Global Market: Forging a New Generation of Business Leaders
Georgetown University, Berkley Center for Religion, Peace & World Affairs
April 30, 2010
Taxpayer Wins LILO Case in the Court of Federal Claims
Real Estate Finance Journal
April 1, 2010
The New Battle In An Old War: Omissions From Gross Income
126 Tax Notes 1227
March 8, 2010
IRS Scrutiny of Equity Swaps Could Impact Offshore Funds
March 5, 2010
National Westminster Bank: Will the IRS Ever Give Up
Corporate Taxation
March 1, 2010
The Curious Case of The Partial Loophole Closer
Corporate Taxation
January 1, 2010
Kiva Dunes and Golf Course Conservation Easements: Important Implications for Tax Deductibility of Conservation Easement Contributions
Free State Accountant
January 1, 2010
Undeclared Foreign Accounts—Voluntary Disclosures and FBARs After the IRS Settlement Initiative
Journal of Tax Practice and Procedure
December 1, 2009
2009 Treaty Developments
Corporate Taxation
November 1, 2009
Summary of Recent Developments for 2009
American Bar Association Section of Taxation, Court Procedure & Practice Committee
September 1, 2009
Sotomayor Record Indicates Penchant for Protectionist State Tax Policies
Tax Foundation
July 16, 2009
Justice Souter's Tax Opinions Show Steady Erosion of Respect for Commerce Clause
Tax Foundation Fiscal Facts, No. 173
June 3, 2009
Comments to the Proposed Amendments to the Rules of the United States Tax Court
American Bar Association
May 27, 2009
Comments to the Proposed Amendments to the Rules of the United States Tax Court
American Bar Association
May 27, 2009
Resolución de Conflictos en Material Fiscal (in Spanish)
Revista - Instituto Colombiano de Derecho Tributario
May 10, 2009
Selected Recent Developments in Administrative Practice
American Bar Association (May Meeting, Administrative Practice Committee)
May 8, 2009
From the House that Ruth Built to the House the IRS Built
Tax Foundation Fiscal Facts, No. 167
April 6, 2009
Cross-Border Information Reporting & Civil Penalities (in a Nutshell)
Journal of Tax Practice & Procedure
April 1, 2009
States Use Gentle Hand in Taxing Timberland
Tax Foundation Fiscal Facts, No. 164
March 25, 2009
Voluntary Disclosure Key to Addressing Offshore Tax Cheats, Practitioners Say
Tax Analysts
December 8, 2008
A $200,000 Penalty for a $25,000 Deduction??!!: the High Price of Failing to Disclose Listed Transactions Under Section 6707A of the Code
November 7, 2008
Summary of Recent Developments for 2008
American Bar Association Section of Taxation, Court Procedure & Practice Committee
September 1, 2008
The Malpractice Environment for Tax Lawyers in the United States
Practice Exposures for the International Tax Professional in the 21st Century, 37 Tax Management International Journal 431
August 8, 2008
The Current State of Expatriation
Guide to International Estate Planning, American Bar Association
June 3, 2008
Conservation Easements Under Fire: A Five-Point Strategy to Defend the Deduction
Maryland Society of Accountants: The Free State Accountant
June 1, 2008
Voluntary Disclosure Becomes A Necessity
International Tax Review
May 1, 2008
Curing Non-Compliance: Practical Factors to Consider in the United States
International Bar Association, International Wealth Transfer Pricing Conference
March 3, 2008
Tax Crimes: Has the Bright Line Moved?
Law Journal Newsletters
February 1, 2008
'Prior Work' Can Create Ethical and Malpractice Risk
ABA Section of Taxation NewsQuarterly
December 1, 2007
IRS Sends Mixed Messages to Nonprofis
POLITICO
October 16, 2007
Developments Aplenty in the KPMG Tax Case: Partial Dismissal, and Court-Ordered Transparency In Entity/Government Negotiations
September 30, 2007
Treasury, IRS Continues Attack on Abusive Tax Transactions: Final Regulations for Reportable Transactions Issued
Derivatives Financial Products Report
September 1, 2007
COMMENT: Deputy-Doctors: The Medical Treatment Exception after Davis v. Washington
43 CAL. W. L. REV. 451, 2007
May 1, 2007
Meeting Newsletter
American Bar Association Section of Taxation, Court Procedure & Practice Committee (2006-2007)
May 1, 2007
ABA's Comments Concerning the Tax Court's Proposed Amendments Regarding Privacy and Public Access to Electronic Case Files
American Bar Association
April 13, 2007
Blame It on Transparency
Tax Notes
March 5, 2007
Pay Immediate Attention to Far-Reaching Regulations on Intercompany Services
Caplin & Drysdale
October 1, 2006
New Penalties for Tax-Exempt Entities and Managers
Caplin & Drysdale
October 1, 2006
Thou Shalt Not Profit, Part I: New Penalties for Tax-Exempt Entities and Managers
Health Lawyers Weekly
September 8, 2006
A Rare Look Inside The IRS's Office of Professional Responsibility
Journal Of Tax Practice and Procedure
May 1, 2006
Deferred Prosecution Agreements: Implications for Corporate Tax Departments
The Tax Executive
February 1, 2006
IRS Launches Settlement Initiative for Certain "Abusive Transactions"
Caplin & Drysdale
January 15, 2006
Proposed Cost-Sharing Regulations Issues
Caplin & Drysdale
January 15, 2006
Tax Planning for Involuntary Conversions
Tax Notes
October 3, 2005
Enhanced IRS Enforcement and the Voluntary Disclosure Policy
International Law Office
August 26, 2005
I'll Pay, but Let's Not Call It a Fine: Code Sec. 162(f) Issues in Structuring Settlement Payments - Five Lessons from LTR 200520241
Taxes - The Tax Magazine
July 5, 2005
Tax Shelter Reform
Caplin & Drysdale
November 1, 2004
Stop the Presses (Book Review)
Law Practice Magazine
September 1, 2004
Foreign Bank Accounts - Last Chance for Taxpayers?
Caplin & Drysdale
July 1, 2004
News on the Transfer Pricing Front
Caplin & Drysdale
July 1, 2004
But I Don't Sell Tax Shelters! The Expanding Reach of the Code Sec. 6700 Promoter Penalty
Taxes - The Tax Magazine
June 1, 2004
Recent Developments in the Tax Shelter Area
Caplin & Drysdale
November 1, 2003
"Hot Interest" for Large Corporate Underpayments
Caplin & Drysdale
November 1, 2003
Transfer Pricing: New Rules for Services and Intangibles
Caplin & Drysdale
November 1, 2003
Corporate Taxation: New Consolidated Return Duplicated Loss Rules
Caplin & Drysdale
April 1, 2003
Tax Advice After Sarbanes-Oxley
Caplin & Drysdale Tax Advice
January 24, 2003
Taxpayer Privacy and Disclosure Issues Will Continue to Touch Us All
The Future of American Taxation (Tax Analysts)
December 1, 2002
Accounting Methods - Which Retroactive 'Corrections' Require IRS Consent?
Tax Lawyer, Vol. 56, No. 101
September 1, 2002
Treasury Department Closing the Door on Tax Shelters
Washington Business Journal
August 5, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
August 1, 2002
The IRS Reorganization: Programs and Initiatives of the New Large Case Division
Administrative Law Review, Vol. 53, No. 2
May 1, 2001
The Disclosure Debate Rages On … And On
89 Tax Notes 419
October 16, 2000
Important Points to Remember: The Disclosure Debate
89 Tax Notes 301
October 9, 2000
Transfer Pricing: A Special Report
International Tax Review Supp. 31
July 1, 2000
Tax-Exempt Bond Issuers Should Welcome an Excise Tax
21-2 Municipal Finance Journal 55
June 1, 2000
The UPS, Limited and Compaq Cases: Is the Tide Turning?
26 International Tax J. No. 3, 1
June 1, 2000
Responses to the 'Lurking Marriage Penalty'
National Law Journal
October 4, 1999
The Hamas Deportation: Israel's Response to Terrorism During the Middle East Peace Process
10 Am. U. J. Intl'l & Pol'y 397
January 1, 1994

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