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Allison, Mark D.
Birkenstock, Joseph M.
Burmester, Kirsten
Caplin, Mortimer M.
Clauson, Jacob T.
Cluett, Ronald G.
Drysdale, Douglas D.
Durham, Michael W.
Elber, Niles A.
Fay Green, Natalie
Fournier, William D.
Grossman, Elizabeth A.
Hicks, Matthew C.
Holmes, Diara M.
Hutson, Courtney
Inselbuch, Elihu
Jaramillo, Victor A.
Jowers, Kirk L.
Kahng, Sean I.
Kaufman, Beth Shapiro
Kelleher, Leslie M.
Keller, Elan P.
Klimon, William M.
Kochman, Neal M.
Koski, Jeanna Rickards
Laughlin, Felix B.
Lewis, Patricia Gimbel
Liesemer, Jeffrey A.
Lloyd, Michael
Lockwood, Peter Van N.
Lowy, Peter A.
Maclay, Kevin C.
Matthews, Mark E.
McDaniel, Brady
McMillan, Ann C.
Mehany, Dianne C.
Michel, Scott D.
Morgan, Bryson B.
Namorato, Cono R.
Nokes, Sharon W.
O'Brien, Jennifer M.
Owens, Marcus S.
Partain, Rachel Leigh
Pfeifer, Michael G.
Phillips, Todd E.
Polk, Shauna
Potter, Trevor
Reinsel, Ronald E.
Rizek, Christopher S.
Rosenbaum, Daniel B.
Rosenbloom, H. David
Ruchelman, Charles M.
Sackett, Andrew J.
Salles, James E.
Sanderson, Matthew T.
Schick, Sharon H.
Skillman, Richard W.
Slocombe, Walter B.
Smiley, Stafford
Swett III, Trevor W.
Tobin, Rita C.
Varley, Douglas N.
Wallace, Clinton G.
Weber, Ann M.
Wehner, James P.
Wilson , Brendan
Youn, Joanne C.
Ziering, Zhanna A.
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International Tax
Alerts
Corporate, Business & 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
International Tax Alert
ALERT: Recent Developments Relating to FBARs and Offshore Voluntary Disclosure Program
June 6, 2011
International Tax Alert
ALERT: Certainty for Reporting Uncertain Tax Positions (UTP) to IRS
October 13, 2010
International Tax Alert
ALERT: Recently Enacted Provisions Relating to the Foreign Tax Credit
October 8, 2010
International Tax Alert
ALERT: More and More Transfer Pricing Enforcement in Store!
August 6, 2010
International Tax Alert
ALERT: IRS Launches New "Transfer Pricing Practice" -- Pilot Program Will Select Audit Cases for Scrutiny
May 5, 2010
International Tax Alert
ALERT: More Foreign Financial Account Reporting
March 26, 2010
International Tax Alert
ALERT: Looking for FBARs in All the Wrong Places? Limited Relief in New Interim Guidance
March 15, 2010
Employee Benefits Alert
ALERT: Get Ready for the Employment Tax Compliance Surge: IRS to Challenge Status of Independent Contractors
February 18, 2010
Publications
Safe at Last? Transfer Pricing Safe Harbors on the Horizon
September 6, 2012
What You Really Need to Know About Transfer Pricing
July 1, 2012
Article from Tax Analysts, Switzerland and the U.S.: What We Have Here is a Failure to Communicate
June 4, 2012
Foreign Tax Credit Generators
May 1, 2012
Offshore Tax Evasion: US Initiatives by Scott D. Michel
April 26, 2012
Before It's Too Late: Reconsidering The IRS Relief for Madoff Losses
February 20, 2012
Taxation of Passive Foreign Investment Companies: Current Rules, Problems and Possible Solutions
November 1, 2011
FATCA & Foreign Bank Accounts: Has the U.S. Overreacted?
May 31, 2011
An Overview of the Foreign Account Tax Compliance Act
April 28, 2011
Short Cuts for Small Fry: Why the IRS Should Reconsider
April 21, 2011
IRS Seeks Names of U.S. Account Holders at HSBC (India)
April 18, 2011
United States: Decoding Cross-Border Tax Compliance: CFCs, PFICs, Foreign Trusts & Foreign Gifts And Bequest
March 1, 2011
Indictment of Offshore Account Holder Portends a New Round of Aggressive Enforcement
February 2011
The First Shoe Drops: Notice 2010-92 Provides Guidance on Section 909's Application to Pre-2011 Taxes
December 15, 2010
The Foreign Account Tax Compliance Act and Notice 2010-60
December 2010
New Foreign Tax Credit Anti-Splitting Rule
November 8, 2010
IRS's Voluntary Disclosure Program for Offshore Accounts: A Critical Assessment After One Year
September 21, 2010
Tax Court Rules That UK Windfall Tax Is Creditable in the United States
September 17, 2010
Advise Client Companies to Review Payroll Practices
September 10, 2010
Federal and State Governments Target Employment Tax Compliance
September/October 2010
Foreign Flow-Through Election’s Effect on Noncompulsory Tax Treatment
July 19, 2010
The Foreign Account Tax Compliance Act
May 11, 2010
IRS Scrutiny of Equity Swaps Could Impact Offshore Funds
March 5, 2010
Undeclared Foreign Accounts—Voluntary Disclosures and FBARs After the IRS Settlement Initiative
December 2009 - January 2010
2009 Treaty Developments
November/December 2009
The New U.S.-Italy Treaty: A U.S. Perspective
August 2009
Addressing the Economic Downturn Under Existing Transfer Pricing Methods
June 22, 2009
Resolución de Conflictos en Material Fiscal (in Spanish)
May 10, 2009
Survival Techniques: Transfer Pricing in a Sick Economy
May-June 2009
Shooting for the Stars
April 20, 2009
Time for a Change: Toward a New Korea-U.S. Income Tax Treaty
April 20, 2009
Cross-Border Information Reporting & Civil Penalities (in a Nutshell)
04/01/2009
Information Reporting and Civil Penalties (In a Nutshell)
December 22, 2008
The IRS Spotlight on Foreign Athletes and Entertainers
November 2008
Foreign Trusts: Everything You Wanted to Know About the Taxation of Foreign Trusts But Were Afraid to Ask
October 2008
Voluntary Disclosure Becomes A Necessity
May 2008
Foreign Trust Reporting and Compliance
March 2008
Deductions for Non-U.S. persons under U.S. Income Tax Laws
March 01, 2008
The Practical Impact of FIN48 - Is it Moving Abroad?
November 1, 2007
Self-Created Transfer Pricing Adjustments
June 4, 2007
Caplin & Drysdale Tax Alert October 2006
October 2006
Proposed Cost-Sharing Regulations Issued
May 2006
Caplin & Drysdale Tax Alert May 2006
May 2006
A New Age in Cost Sharing? The IRS Proposed Regulations
December 9, 2005
Enhanced IRS Enforcement and the Voluntary Disclosure Policy
August 2005
Caplin & Drysdale Tax Alert
June 2005
Caplin & Drysdale Tax Alert
February 2005
Caplin & Drysdale Tax Alert
November 2004
U.S. Issues Guidance on Apportionment of Charitable Contributions to U.S.-Source Income
August 9, 2004
Russia: A "Virtual" Democracy
August 2004
Caplin & Drysdale Tax Alert
July 2004
TNI Interview: H. David Rosenbloom
May 10, 2004
Banes of an Income Tax: Legal Fictions, Elections, Hypothetical Determinations, Related Party Debt*
March 2004
Think About Subpart F: The Domestic Base Company
March 2004
India: Great Potential and Promise
February 2004
Banes of an Income Tax: Legal Fictions, Elections, Hypothetical Determinations, And Related Party Debt
December 15, 2003
Why Not Des Moines? A Fresh Entry in the Subpart F Debate
December 8, 2003
Markers and Musings: The Proposed Section 482 Service Regulations
November/December 2003
Caplin & Drysdale TaxAlert
November 2003
An Awakening Giant: China and the New Civil Society
October 2003
Russia in Transition
September 2003
Testimony of David Rosenbloom Before the U.S. Senate Committee on Finance
July 15, 2003
Caplin & Drysdale TaxAlert
April 2003
Option Wars: Upping the Ante for Cost Sharing Arrangements
November 8, 2002
Second First?? Transfer Pricing Issues In Secondment of Personnel
July-August 2002
Deconstructing Section 905(c): An Examination of The Redetermination Rules After TRA 1997
April 2002
Taxes Covered By §960(a)(3)
February 8, 2002
From the Bottom Up: Taxing the Income of Foreign Controlled Corporations
September 2001
Arbitrage and Transfer Pricing Paper
Fall 2000
Cost-Sharing Arrangements Come of Age
August 28, 2000
Mining For Nuggets in the IRS APA Report
May/June 2000
Transfer Pricing Thoughts - North America: More Thoughts On APA Disclosure
March 2000
Caplin & Drysdale TaxAlert
February 2000
Treaties and Interest Expense Allocation: Moving in a Natwesterly Direction
January 2000
Foreign Income Portfolios: U.S. Income Taxation of Foreign Corporations
January 2000 (co-authored by Charles T. Plambeck)
Transfer Pricing Thoughts - North America: Thoughts on Code Sec. 482 and Rising Standards of Proof
December 1999/January 2000
Transfer Pricing Thoughts - North America: Thoughts on Control
October/November 1999
Transfer Pricing Thoughts - North America: Thoughts on Cooperatives
August/September 1999
Transfer Pricing Thoughts - North America: Thoughts on APA Disclosure
June/July 1999
The "Ins" "Outs" "Overs" and "Unders" of the New Global Netting Rules
April 1999
Transfer Pricing Thoughts - North America: The Euro and the Situs of the Borrower Rule
April/May 1999
Transfer Pricing Thoughts - North America: Thoughts on Joint Ventures
February/March 1999
Navigating the Global Netting Rules: Uncertainties Abound in Interest Rate Calculation Process Under New Law
December 1998
U.S. Proposed Global Trading Regs: Preliminary Questions Regarding Application
May 1998
Commentary: Caplin & Drysdale Blasts Proposed Foreign Tax Credit Regs
May 1997