Publications

• A New Recipe for Election Reform
  May 9, 2013
  
• A Simple Plan to Drastically Improve Voting, Stop Fraud, and Save Money
  April 18, 2013
  
• Stipulation Limiting Damages Cannot Circumvent CAFA Jurisdiction
  March 26, 2013
  
• The Effrontery of The Asbestos Trust Transparency Legislation Efforts
  February 20, 2013
  
• Demystifying the IRS Guidance Process
  February 1, 2013
  
• Campaign Finance: Remedies Beyond the Court
  January 8, 2013
  
• U.K. Excess Profits Tax Under U.S. Foreign Tax Credit
  January 1, 2013
  
• FATCA: A New Era of Financial Transparency
  January 1, 2013
  
• The Nuts And Bolts of Deficiency Cases: From Examination to The Tax Court
  December 1, 2012
  
• Supreme Court to Consider Impact of Stipulation Limiting Damages on CAFA Jurisdiction
  September 10, 2012
  
• Primary Concerns: Canvassing Transfer Tax Proposals
  June 1, 2012
  
• Hedge Fund Managers Beware:Unless Claims are Assigned, Managers Do Not Have Standing to Sue for Their Funds
  February 15, 2012
• Protecting Yourself and Your Client in a Joint Defense Arrangement
  Winter 2012
• Guidance from the IRS: The Logjam Finally Breaks
  December 1, 2011
• The Federal Estate and Gift Tax: A Case Study in Uncertainty
  December 2011
• Offshore Tax Enforcement, Voluntary Disclosure, And Undeclared Foreign Accounts
  December 2011
• Israel: A Strategic Asset for the United States
  November 3, 2011
• Taxation of Passive Foreign Investment Companies: Current Rules, Problems and Possible Solutions
  November 1, 2011
• OVDI Is Over — What's Next for Voluntary Disclosures?
  October 17, 2011
• Making Their Mark: The Supreme Court Clarified and Reshaped Class Action Law in the October 2010 Term
  August 1, 2011
• Unreported Gifts of Real Property: Time for a Voluntary Disclosure?
  August 1, 2011
• Social Media at Work: Defining New Legal Boundaries
  July-August 2011
• United States Supreme Court Holds That Loss Causation Is Not Required to Obtain Class Certification in a Securities Class Action
  June 13, 2011
• FATCA & Foreign Bank Accounts: Has the U.S. Overreacted?
  May 31, 2011
• Finally Legislation! Congress Kicks the Can Down the Road
  June 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
• Executive Compensation Plans
  November 8, 2010
• New Foreign Tax Credit Anti-Splitting Rule
  November 8, 2010
• Evolving Fiduciary Duties in the Era of Financial Reform
  September 22, 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
• Four Common IRS Church Audit Issues
  Third Quarter, 2010
• Foreign Flow-Through Election’s Effect on Noncompulsory Tax Treatment
  July 19, 2010
• Once Again Employment Tax Compliance at the Forefront of IRS's Enforcement Agenda
  June 21, 2010
• Utah's Way of Picking Candidates Robs Voters
  June 21, 2010
• Virginia Is for Lovers and Fraudsters
  June 3, 2010
• The Foreign Account Tax Compliance Act
  May 11, 2010
• 2010: The Anatomy of a Train Wreck
  May 2010
• IRS Scrutinizes Payroll Practices, Challenges for Companies
  May 2010
• IRS Scrutiny of Equity Swaps Could Impact Offshore Funds
  March 5, 2010
• Estate Tax Expires - for Now
  January 7, 2010
• Kiva Dunes and Golf Course Conservation Easements: Important Implications for Tax Deductibility of Conservation Easement Contributions
  January/February 2010
• Budget and Health Care and Taxes. Oh My!
  December 2009
• Undeclared Foreign Accounts—Voluntary Disclosures and FBARs After the IRS Settlement Initiative
  December 2009 - January 2010
• What Will Healthcare Legislation Hold for Nonprofit Hospitals?
  November/December 2009
• 2009 Treaty Developments
  November/December 2009
• The Final State of Expatriation? - Part I
  October 1-2, 2009
• The Final State of Expatriation? - Part II
  September 28, 2009
• Congress Can Better Voter Registration
  September 14, 2009
• Money Business: Constitutional Opinions
  September 11, 2009
• The New U.S.-Italy Treaty: A U.S. Perspective
  August 2009
• Estate Tax Legislation in 2009: Avoiding the Train Wreck
  July 2009
• A New Page for Voting: It's Time to Ditch Paper-Based Registration
  June 25, 2009
• Addressing the Economic Downturn Under Existing Transfer Pricing Methods
  June 22, 2009
• Sanderson: Analysis of Bill Clinton's Cybersquatting Loss
  June 4, 2009
• Senior Lawyer Mortimer Caplin Receives Two Prestigious Awards
  June 1, 2009
• Private Foundations and the Protection of Assets
  June 1, 2009
• Resolución de Conflictos en Material Fiscal (in Spanish)
  May 10, 2009
• Next Phase of Election Reform: Start with Facts
  May 5, 2009
• ".Pol", a ".Com" for Political Candidates
  May 1, 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
• A Dot-Pol of Their Own
  April 11, 2009
• Two Birds, One Stone: Reversing “Frontloading” by Fixing the Presidential Public Funding System
  April 2009
• GAO Report on Lobbying Disclosure
  April 6, 2009
• Cross-Border Information Reporting & Civil Penalities (in a Nutshell)
  04/01/2009
• IRS Releases Hospital Report: Response from Capitol Hill
  March 12, 2009
• Candidates, Squatters and Gripers: A Primer on Political Cybersquatting and A Proposal for Reform
  January 2009
• Information Reporting and Civil Penalties (In a Nutshell)
  December 22, 2008
• Voluntary Disclosure Key to Addressing Offshore Tax Cheats, Practitioners Say
  December 8, 2008
• Checking in with the Guidance Department
  December 2008
• Charities and Governance: Is the IRS Subject to Challenge?
  November 18, 2008
• The IRS Spotlight on Foreign Athletes and Entertainers
  November 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 2008
• Foreign Trusts: Everything You Wanted to Know About the Taxation of Foreign Trusts But Were Afraid to Ask
  October 2008
• The Best Lawyers in America 2009 Ranks Caplin & Drysdale as #1 in Tax Law
  October 2008
• IRS Issues Revised Foreign Account Reporting Form
  October 2008
• From Intent to Outcome: Balloting and Tabulation Around the World
  October 2008
• Credit Default Swaps & the Bankrupt Counterparty - Entering the Undiscovered Country
  September 2008
• Separating Exempt-Purpose & Non-Exempt-Purpose Activities
  September/October 2008
• Sound and Fury, Signifying What? The U.S. Foreign Earned Income Exclusion Debate
  September 15, 2008
• Voodoo Economics: A Look Abroad for a Supply-Side Solution to America's Campaign Finance Riddle
  September 2008
• From Arbitration to Zero Withholding: A Primer on the U.S.-Canada Treaty Protocol
  August 2008
• The IRS’s New Whistleblower Program – Another Enforcement Alert for International Business
  July 2008
• Conservation Easements Under Fire: A Five-Point Strategy to Defend the Deduction
  June 2008
• Hearing It Out
  June 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
• Tax Crimes: Has the Bright Line Moved?
  February 2008
• Money Adds New Dimension to 'Veepstakes'
  December 5, 2007
• Gazing into the Crystal Ball: a Prediction of Post-Election Action
  December 2007
• The Practical Impact of FIN48 - Is it Moving Abroad?
  November 1, 2007
• Developments Aplenty in the KPMG Tax Case: Partial Dismissal, and Court-Ordered Transparency In Entity/Government Negotiations
  September 2007
• Self-Created Transfer Pricing Adjustments
  June 4, 2007
• Legislative Paralysis
  June 1, 2007
  
• Supporting Organization Provisions Of The Pension Protection Act Of 2006
  April 2007
• Caplin & Drysdale Tax Alert May 2007
  May 1, 2007
  
• Blame It on Transparency
  March 5, 2007
• Charitable Giving Incentives and Reforms in the Pension Protection Act
  January/February 2007
• Caplin & Drysdale Tax Alert October 2006
  October 2006
• D.C. Circuit Extends Supreme Court's Interpretation of 'Derivative Use' Under 'Act of Production' Immunity
  September 2006
• Caplin & Drysdale Tax Alert May 2006
  May 2006
• A Rare Look Inside The IRS's Office of Professional Responsibility
  April/May 2006
• Proposed Cost-Sharing Regulations Issued
  May 2006
• Deferred Prosecution Agreements: Implications for Corporate Tax Departments
  January/February 2006
• Caplin & Drysdale Tax Alert
  January 2006
• A New Age in Cost Sharing? The IRS Proposed Regulations
  December 9, 2005
• Tax Planning for Involuntary Conversions
  October 3, 2005
• August 2005
  August 2005
• Enhanced IRS Enforcement and the Voluntary Disclosure Policy
  August 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
  July 2005
• Caplin & Drysdale Tax Alert
  June 2005
• TSUNAMI: NGO’s Response: Now and the Future
  February 2005
• Caplin & Drysdale Tax Alert
  February 2005
• Tax Accounting Monthly Column
  January 2005
• Technology Transfer and the New Economy
  January 2005
• The IRS Office of Professional Responsibility
  December 2004
• Tax Accounting Monthly Column
  December 2004
• Criminal Tax Investigations and Current Year Returns: New Thoughts on a Perennial Issue
  December 2004
• Caplin & Drysdale Tax Alert
  November 2004
• Tax Accounting Monthly Column
  September 2004
• Politics and the Pulpit
  September 22, 2004
• Playing by the Rules
  September 2004 (Published in October 1998)
• U.S. Issues Guidance on Apportionment of Charitable Contributions to U.S.-Source Income
  August 9, 2004
• Tax Accounting Monthly Column
  August 2004
• Russia: A "Virtual" Democracy
  August 2004
• Caplin & Drysdale Tax Alert
  July 2004
• But I Don't Sell Tax Shelters! The Expanding Reach of the Code Sec. 6700 Promoter Penalty
  June 2004
• TNI Interview: H. David Rosenbloom
  May 10, 2004
• Caplin & Drysdale TaxAlert
  April 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
• Corporate Tax Departments and the New Focus on Corporate Criminality
  November/December 2003
• Tax Accounting Monthly Column
  November 2003
• Caplin & Drysdale TaxAlert
  November 2003
• An Awakening Giant: China and the New Civil Society
  October 2003
• Tax Accounting Monthly Column
  October 2003
• Russia in Transition
  September 2003
• Tax Accounting Monthly Column
  September 2003
• Tax Accounting Monthly Column
  August 2003
• Testimony of David Rosenbloom Before the U.S. Senate Committee on Finance
  July 15, 2003
• Tax Accounting Monthly Column
  July 2003
• If I Had a Hammer
  September 2003
• Codification of Economic Substance
  May 7, 2003
• Tax Accounting Monthly Column
  May 2003
• Tax Accounting Monthly Column
  April 2003
• Caplin & Drysdale TaxAlert
  April 2003
• Tax Accounting Monthly Column
  March 2003
• Tax Accounting Monthly Column
  February 2003
• Tax Advice After Sarbanes-Oxley
  January 24, 2003
• Donor Intent: Preserving the Mission of Charitable Foundations
  January 2003
• Tax Accounting Monthly Column
  December 2002
• Option Wars: Upping the Ante for Cost Sharing Arrangements
  November 8, 2002
• Tax Accounting Monthly Column
  November 2002
• The Tax Court Decides the Opening Skirmish in Intermediate Sanctions Litigation
  November/December 2002
• Tax Accounting Monthly Column
  October 2002
• Second First?? Transfer Pricing Issues In Secondment of Personnel
  July-August 2002
• Tax Accounting Monthly Column
  September 2002
• Letter Ruling Alert: A Blueprint for Creating a Taxable Subsidiary
  August 2002
• The Viability of Multidisciplinary Practice
  August 2002
• Tax Accounting Monthly Column
  August 2002
• The Importance of Transparency: A Review of the Public Disclosure Rules
  Second Quarter 2002
• Tax Accounting Monthly Column
  July 2002
• Of Merchandise, Accruals, And Administrative Grace
  June 17, 2002
• Tax Accounting Monthly Column
  June 2002
• Tax Accounting Monthly Column
  May 2002
• The Viability of Mulitdisciplinary Practice
  May 2002
• Caplin & Drysdale TaxAlert
  April 2002
• Tax Accounting Monthly Column
  April 2002
• Deconstructing Section 905(c): An Examination of The Redetermination Rules After TRA 1997
  April 2002
• Tax Accounting Monthly Column
  March 2002
• IRS Form 990 Donor Disclosure
  March 2002
• Taxes Covered By §960(a)(3)
  February 8, 2002
• Tax Accounting Monthly Column
  February 2002
• Disaster Relief Activities of Charitable Organizations
  February 2002
• Tax Accounting Monthly Column
  January 2002
• Tax Accounting Monthly Column
  December 2001
• Letter Ruling Alert: A New Twist in Donations of Stock Options By Disqualified Persons
  December 2001
• Tax Accounting Monthly Column
  November 2001
• Letter Ruling Alert: Round Income, Square Tax Code
  November 2001
• The Tax Consequences of Accepting Charitable Contributions Through a Single-Member LLC
  November/December 2001
• Tax Accounting Montly Column
  October 2001
• Letter Ruling Alert: PRI Possibilities in the Age of Venture Philanthropy: Foundation's Investment in Environmental Venture-Capital Fund Qualifies as a Program-Related Investment
  October 2001
• From the Bottom Up: Taxing the Income of Foreign Controlled Corporations
  September 2001
• Letter Ruling Alert: Service Excludes Ministers' Housing Allowances from Compensation for Purposes of Determining Retirement Plan Contribution Limits
  September 2001
• Tax Accounting Monthly Column
  September 2001
• The State of Lawyering
  Fall 2001
• Tax Accounting Monthly Column
  August 2001
• Exempt Organizations Tax Update
  August 2001
• Estate, Gift, and Generation-Skipping Taxes: The Implications of the Economic Growth and Tax Relief Reconciliation Act of 2001
  July 2001
• Tax Accounting Monthly Column
  July 2001
• Contingent Fees and Tort Reform: A Reassessment and Reality Check
  Spring/Summer 2001
• Income Tax Changes, Estate Tax Changes And Implications for Charitable Giving Of the Economic Growth and Tax Relief Reconciliation Act of 2001
  July 2001
• Tax Accounting Monthly Column
  June 2001
• 'If Americans Really Understood The Income Tax'
  May 28, 2001
• Tax Accounting Monthly Column
  May 2001
• President Bush Presents His Tax Plans for Charitable Giving
  May/June 2001
• Tax Accounting Monthly Column
  April 2001
• Caplin Calls for Fairness and Simplification in New Tax Legislation
  March 5, 2001
• Tax Accounting Monthly Column
  March 2001
• Tax-Exempt Organizations and the Internet: Tax and Other Legal Issues
  March 2001
• Now Is the Time to Reform the Tax Code
  February 7, 2001
• Tax Accounting Monthly Column
  February 2001
• Tax Accounting Monthly Column
  January 2001
• Letter Ruling Alert: Charities and Election-Year Politics - The Transformation of a Public Figure's Charity Fund-Raising Letter into a Charity-Sponsored Campaign Advertisement
  December 2000
• Teaching Taxation: Following the Money in the 2000 Election
  December 2000
• Tax Accounting Monthly Column
  December 2000
• Congress Requires Disclosure by Section 527 Organizations
  November/December 2000
• Tax Accounting Monthly Column
  November 2000
• Letter Ruling Alert: Shades of Revenue Ruling 98-15 - Ancillary Joint Ventures Between Tax-Exempt Organizations and For-Profit Entities
  November 2000
• Tax Accounting Monthly Column
  October 2000
• Arbitrage and Transfer Pricing Paper
  Fall 2000
• Tax Accounting Monthly Column
  September 2000
• Cost-Sharing Arrangements Come of Age
  August 28, 2000
• Tax Accounting Monthly Column
  August 2000
• Tax Accounting Monthly Column
  July 2000
• Tax Workouts and Procedures During and After the IRS Restructuring
  June 2000
• Tax Accounting Monthly Column
  June 2000
• Tax Accounting Monthly Column
  May 2000
• Mining For Nuggets in the IRS APA Report
  May/June 2000
• Weighing the Alternatives to Private Foundations
  May/June 2000
• Tax-Exempt Organizations and the Internet (Part 2)
  Spring 2000 (co-authored by Amy R. Segal)
• Tax Accounting Monthly Column
  April 2000
• Tax Accounting Monthly Column
  March 2000
• Letter Ruling Alert: The Door Opens - Structuring Royalty & Service Arrangements
  March 2000
• Transfer Pricing Thoughts - North America: More Thoughts On APA Disclosure
  March 2000
• Caplin & Drysdale TaxAlert
  February 2000
• Bob Jones Revisited
  February 2000
• Tax Accounting Monthly Column
  February 2000
• Treaties and Interest Expense Allocation: Moving in a Natwesterly Direction
  January 2000
• Tax-Exempt Organizations and the Internet (Part 1)
  Winter 2000 (co-authored by Amy R. Segal)
• The 1969 Private Foundation Law: Historical Perspective on its Origins and Underpinnings
  January 2000
• Tax Accounting Monthly Column
  January 2000
• Foreign Income Portfolios: U.S. Income Taxation of Foreign Corporations
  January 2000 (co-authored by Charles T. Plambeck)
• Private Foundation Grants to Public Charities Engaged in Advocacy on Environmental Issues
  December 1999
• Tax Accounting Monthly Column: Bank's Loan Origination Costs Emerge As a High-Profile Issue
  December 1999
• Environmental Protection: The Relationship with Human Rights
  December 1999
• Transfer Pricing Thoughts - North America: Thoughts on Code Sec. 482 and Rising Standards of Proof
  December 1999/January 2000
• Tax Accounting Monthly Column: Clear Reflection Principles May Work For Taxpayers Too
  November 1999
• Letter Ruling Alert: A New Option for Private Foundation Investing
  November 1999
• Tax Accounting Monthly Column: IRS Wins Before the Tax Court in Norwest
  October 1999
• Transfer Pricing Thoughts - North America: Thoughts on Control
  October/November 1999
• Taxation and Transition: Nonprofit Organizations in a Market Economy
  September 1999
• At the Front--New Institute Propels Reform Efforts
  September 1999
• Advising a Client with Secret Offshore Accounts - Current Filing and Reporting Problems
  September 1999
• Transfer Pricing Thoughts - North America: Thoughts on Cooperatives
  August/September 1999
• When Is Tax Practice 'Legal'?
  July 5, 1999
• Minimizing Risk and Maximizing Benefits Under the Final Disclosure Regs. For Exempt Organizations
  July 1999
• Transfer Pricing Thoughts - North America: Thoughts on APA Disclosure
  June/July 1999
• New Technologies in Retirement Plan Administration
  May 1999
• Tax Court Rules (Again) on Sierra Club Affinity Card Income
  May 1999
• Letter Ruling Alert: Rendering Unto Caesar
  May 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
• How the IRS Plans to Restructure Its Exempt Organization Operations
  April 1999
• IRS Intermediate Sanctions: How They Will Impact Colleges and Universities
  Spring 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
• Strategies for Filing a Tax Return While Under a Criminal Tax Investigation
  September 1996