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Allison, Mark D.
Armitage, J. Clark
Barnes, Peter A.
Barzell, Dustin J.
Biss, Meghan R.
Black, Jonathan R.
Brenner, Jonathan S.
Burmester, Kirsten
Caplin (1916 - 2019), Mortimer M.
Carney, Leila D.
Carney, Robert T.
Child, Josiah
Davis, Kevin M.
Dlott , Moshe A.
Drysdale (1924 - 2018), Douglas D.
Egan, Alison F.
Eisenstat, Benjamin Z.
Elber, Niles A.
Esman, Aaron M.
Fournier, William D.
Goon , Michael
Hannes, Steven P.
Jaramillo, Victor A.
Kaufman, Beth Shapiro
Kelleher, Leslie M.
Klimon, William M.
Kochman, Neal M.
Koski, Jeanna Rickards
Laughlin, Felix B.
Leon, Amanda M.
Lewis, Patricia Gimbel
Liesemer, Jeffrey A.
Maclay, Kevin C.
Marshall, Olivia N.
Matthews, Mark E.
McMillan, Ann C.
Mehany, Dianne C.
Michel, Scott D.
Miller, Nathaniel R.
Morgan, Bryson B.
Namorato, Cono R.
O'Brien, Anne J.
O'Connor, George M.
Partain, Rachel L.
Phillips, Todd E.
Polk, Shauna
Potter, Trevor
Racicot, Sarah J.
Reed, Amanda
Rizek, Christopher S.
Rosenbaum, Daniel B.
Rosenbloom, H. David
Ruchelman, Charles M.
Sackett, Andrew J.
Salles, James E.
Sanderson, Matthew T.
Schick, Sharon H.
Scott, Leighanne
Sharkey, Ross R.
Skillman, Richard W.
Slocombe, Walter B.
Smiley, Stafford
Stevens, Elizabeth J.
Varley, Douglas N.
Want, Sharon P.
Wehner, James P.
Wernke, Megan E.
Yoon, Sae Jin
Ziering, Zhanna A.
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By Practice Area:
International Tax
Alerts
International Tax Alert
OECD Announces a Public Consultation for Global Minimum Tax Rules
November 25, 2019
International Tax Alert
An OECD "Unified Approach" to Addressing the Challenges of the Digital Economy
November 4, 2019
International Tax Alert
The Proposed GILTI High Tax Exclusion
July 1, 2019
Business, Investment & Transactional Tax Alert
Proposed Regulations Under Section 956
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
IRS Launches 13 Issue-Based Corporate Compliance Campaigns
February 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
Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations
November 3, 2016
Tax Alert
Treasury Announces Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership
April 5, 2016
International Tax Alert
Is It the Real Thing? The IRS Makes $9+ Billion of Transfer Pricing Adjustments Against The Coca-Cola Company
December 23, 2015
Tax Alert
Congress Enacts Entirely New Tax Examination and Collection Regime for Partnerships
December 10, 2015
Private Client Alert
Steps Foreign Persons Can Take to Avoid Unnecessary U.S. Estate Tax
November 9, 2015
International Tax Alert
The Final OECD BEPS Tome Has Arrived
October 8, 2015
International Tax Alert
Strategic Resets Under the New MAP and APA Revenue Procedures
September 23, 2015
International Tax Alert
Transfer Pricing Audits: Flipping the Tested Party
August 13, 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
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
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
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
International Tax Alert
Recent Developments Relating to FBARs and Offshore Voluntary Disclosure Program
June 6, 2011
International Tax Alert
Certainty for Reporting Uncertain Tax Positions (UTP) to IRS
October 13, 2010
International Tax Alert
Recently Enacted Provisions Relating to the Foreign Tax Credit
October 8, 2010
International Tax Alert
More and More Transfer Pricing Enforcement in Store!
August 6, 2010
International Tax Alert
IRS Launches New "Transfer Pricing Practice" -- Pilot Program Will Select Audit Cases for Scrutiny
May 5, 2010
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
Go BIG! How to Build a Tax Effort Worthy of the Belt and Road Initiative
Journal of International Taxation in China
December 11, 2019
U.S. Tax Policy and Cross-Border Investments in 2019: The General Picture
Rivista di Diritto Tributario Internazionale - International Tax Law Review
November 12, 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
Combating Aggressive Tax Planning Through Disclosure: A Comparison of U.S. and EU Rules Applicable to Tax Advisors
ABA Tax Times
June 14, 2019
Agency PE: Case Study, Questions and Expert Speak
IFA India Newsletter
January 1, 2019
Navigating QBAI Quirks of the GILTI Regulations
Bloomberg Tax, Tax Management International Journal
November 5, 2018
SPECIAL REPORT: The Nitty-Gritty of FDII
Tax Notes
October 22, 2018
COMMENTARY & ANALYSIS: The BEAT and the Treaties
Tax Notes International Magazine
October 15, 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
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
Foreword for Asian Voices: BEPS and Beyond
International Bureau of Fiscal Documentation (IBFD)
July 1, 2017
BEPS: The Corporate Tax Leader's Perspective
International Bureau of Fiscal Documentation (IBFD)
July 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
U.S. Corporate Tax Reform and Jean-Paul Sartre
Tax Notes
March 1, 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
The U.S. Must Avoid This Untested Approach To International Taxes
The Hill Op-Ed
January 24, 2017
Tax Plans Compared (December 2016) Corporate Tax
Global Tax Weekly
January 5, 2017
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
The U.S. Country-by-Country Reporting Regulations: A Synopsis
Global Taxation
October 1, 2016
U.S. Tax Enforcers React to The Panama Papers
IFC Review
September 1, 2016
Muhammad Ali in the Time of the 'Maxi Tax'
Tax Notes
August 8, 2016
Financier Worldwide 2016 Global Tax Annual Review – United States
Financier Worldwide
April 27, 2016
DOL Releases 2015 Form 5500 Including New IRS Compliance Questions
International Law Office
March 11, 2016
Coca-Cola Company Challenges $9 Billion Transfer Pricing Adjustment
International Law Office
February 5, 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
IRS Releases Guidance on Voluntary 2015 PPACA Information Reporting
International Law Office
October 2, 2015
Steering the Cadillac Tax: An Additional Opportunity for Employers and Other Stakeholders
International Law Office
September 18, 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
Transfer Pricing Audits: Flipping the Tested Party
Wolters Kluwer
August 27, 2015
IRS Releases Guidelines for Examining CFC Transactions
International Law Office
August 21, 2015
The Need for Federal Oversight of Tax Preparers
University of Pennsylvania Law School, The Regulatory Review
August 10, 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
Steering the Cadillac Tax: An Opportunity for Employers and Other Stakeholders
International Law Office
March 20, 2015
IRS Releases Additional Guidance on Reporting Health Coverage Information
International Law Office
March 13, 2015
Abusive Small Captive Insurance Companies on IRS 'Dirty Dozen' List
International Law Office
February 27, 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
OECD Releases Finalized Proposals on Key Tax Base Erosion Concerns
Global Tax Weekly
November 6, 2014
IRS Issues Final Regulations On Material Advisor Penalties
Global Tax Weekly
September 4, 2014
IRS Issues Final Regulations on Material Adviser Penalties
International Law Office
August 29, 2014
Recent IRS Activity Focuses on Non-Qualified Deferred Compensation Plans
International Law Office
July 25, 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
The New APMA Procedures — Cosmetic or Cosmic?
Tax Management International Journal
March 14, 2014
Surprise! Your Foreign Tax Credit Is Not Allowed Under Section 901(I)
Tax Notes International
January 14, 2014
A New Tax-and-Spend Strategy to Fight Obesity
University of Pennsylvania Law School, The Regulatory Review
January 6, 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
Overview of the OECD'S Action Plan on Base Erosion and Profit Shifting
Corporate Taxation
November 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
FATCA Reporting – Are Trusts and Trustees Caught in the Net?
Financier Worldwide
July 1, 2013
Global Netting: Potential Opportunities for Corporate Taxpayers
WTE Practical International Tax Strategies, Volume 17, Number 8
April 30, 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
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
Safe at Last? Transfer Pricing Safe Harbors on the Horizon
Bloomberg BNA
September 6, 2012
What You Really Need to Know About Transfer Pricing
The Metropolitan Corporate Counsel, Inc.
July 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
Foreign Tax Credit Generators
Corporate Taxation
May 1, 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
Before It's Too Late: Reconsidering The IRS Relief for Madoff Losses
Tax Notes
February 20, 2012
Commissionaire and Contract Manufacturing Arrangements - New Developments on Permanent Establishment Issue
Corporate Taxation
January 1, 2012
The APA Program's Experience With Rev. Proc. 2008-31: Increased Opportunities for Certainty
Bloomberg BNA Tax Management Memorandum
November 7, 2011
Taxation of Passive Foreign Investment Companies: Current Rules, Problems and Possible Solutions
Corporate Taxation
November 1, 2011
2010 Treaty Developments
Corporate Taxation
November 1, 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
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
ITPF - Georgetown University Law Center Conference on Reform of International Tax
Corporate Taxation
May 1, 2011
An Overview of the Foreign Account Tax Compliance Act
American Bar Association, 22nd Annual Spring Symposia
April 28, 2011
Short Cuts for Small Fry: Why the IRS Should Reconsider
BNA Tax Management-Transfer Pricing Report
April 21, 2011
IRS Seeks Names of U.S. Account Holders at HSBC (India)
Taxmann-The Tax & Corporate laws of India-International Tax
April 18, 2011
Putting an End to Foreign Tax Credit 'Splitting' Transactions
Corporate Taxation
March 1, 2011
United States: Decoding Cross-Border Tax Compliance: CFCs, PFICs, Foreign Trusts & Foreign Gifts And Bequest
Mondaq Business Briefing
March 1, 2011
Indictment of Offshore Account Holder Portends a New Round of Aggressive Enforcement
International Taxation
February 1, 2011
President Obama's Efforts at International Tax Reform
Corporate Taxation
January 1, 2011
The First Shoe Drops: Notice 2010-92 Provides Guidance on Section 909's Application to Pre-2011 Taxes
14 Practical International Tax Strategies
December 15, 2010
The Foreign Account Tax Compliance Act and Notice 2010-60
International Taxation
December 1, 2010
New Foreign Tax Credit Anti-Splitting Rule
Tax Notes
November 8, 2010
IRS's Voluntary Disclosure Program for Offshore Accounts: A Critical Assessment After One Year
BNA Insights
September 21, 2010
Tax Court Rules That UK Windfall Tax Is Creditable in the United States
International Law Office
September 17, 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
Foreign Flow-Through Election’s Effect on Noncompulsory Tax Treatment
Tax Notes International
July 19, 2010
A Shift Toward Consumption Taxes: The Tax Policy Prescription For The Fiscal Ills of The Global Financial Crisis
Corporate Taxation
July 1, 2010
The Foreign Account Tax Compliance Act
May 11, 2010
Loan Guarantees and Transfer Pricing
Corporate Taxation
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
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
The New U.S.-Italy Treaty: A U.S. Perspective
Diritto e Pratica Tributaria Internazionale
August 1, 2009
Addressing the Economic Downturn Under Existing Transfer Pricing Methods
Tax Notes International
June 22, 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
Survival Techniques: Transfer Pricing in a Sick Economy
The Tax Executive
May 1, 2009
Time for a Change: Toward a New Korea-U.S. Income Tax Treaty
Tax Notes International
April 20, 2009
Shooting for the Stars
WebCPA
April 20, 2009
Cross-Border Information Reporting & Civil Penalities (in a Nutshell)
Journal of Tax Practice & Procedure
April 1, 2009
Information Reporting and Civil Penalties (In a Nutshell)
December 22, 2008
The IRS Spotlight on Foreign Athletes and Entertainers
Mondaq Business Briefing
November 7, 2008
Foreign Trusts: Everything You Wanted to Know About the Taxation of Foreign Trusts But Were Afraid to Ask
MICPEL, Beyond QDOTs: International Estate Planning for a Flat World
October 23, 2008
A Model to Celebrate
OECD Observer
October 1, 2008
In Praise of the OECD Model Tax Treaty
Worldwide Tax Daily
September 23, 2008
The Current State of Expatriation
Guide to International Estate Planning, American Bar Association
June 3, 2008
Coming Full Circle? Secondary Adjustments and Repatriation in Transfer Pricing Cases
Tax Management Transfer Pricing Report, Bloomberg BNA
May 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
Deductions for Non-U.S. Persons Under U.S. Income Tax Laws
International Tax Planning
March 1, 2008
The Practical Impact of FIN48 - Is it Moving Abroad?
November 1, 2007
Treasury, IRS Continues Attack on Abusive Tax Transactions: Final Regulations for Reportable Transactions Issued
Derivatives Financial Products Report
September 1, 2007
Self-Created Transfer Pricing Adjustments
Tax Notes International
June 4, 2007
COMMENT: Deputy-Doctors: The Medical Treatment Exception after Davis v. Washington
43 CAL. W. L. REV. 451, 2007
May 1, 2007
Pay Immediate Attention to Far-Reaching Regulations on Intercompany Services
Caplin & Drysdale
October 1, 2006
Play it Again Sam – The IRS (More or Less) Finishes the Section 482 Services Regulations
The Tax Executive
October 1, 2006
Tax Alert
Caplin & Drysdale
May 1, 2006
Proposed Cost-Sharing Regulations Issued
Practical US/Domestic Tax Strategies
May 1, 2006
Proposed Cost-Sharing Regulations Issues
Caplin & Drysdale
January 15, 2006
A New Age in Cost Sharing? The IRS Proposed Regulations
Tax Management International Journal
December 9, 2005
Enhanced IRS Enforcement and the Voluntary Disclosure Policy
International Law Office
August 26, 2005
Tax Alert
Caplin & Drysdale
June 15, 2005
The Law of Unintended Consequences: International Implications of Section 409A
The Tax Executive
April 1, 2005
Tax Alert
Caplin & Drysdale
February 1, 2005
U.S. Issues Guidance on Apportionment of Charitable Contributions to U.S.-Source Income
Tax Notes International
August 9, 2004
Russia: A "Virtual" Democracy
The Exempt Organization Tax Review
August 1, 2004
News on the Transfer Pricing Front
Caplin & Drysdale
July 1, 2004
TNI Interview: H. David Rosenbloom
Tax Notes International
May 10, 2004
Banes of an Income Tax: Legal Fictions, Elections, Hypothetical Determinations, Related Party Debt*
The Sydney Law Review
March 30, 2004
Think About Subpart F: The Domestic Base Company
The Tax Magazine
March 15, 2004
India: Great Potential and Promise
The Exempt Organization Tax Review
February 25, 2004
Banes of an Income Tax: Legal Fictions, Elections, Hypothetical Determinations, And Related Party Debt
Tax Notes International
December 31, 2003
Why Not Des Moines? A Fresh Entry in the Subpart F Debate
Tax Notes International
December 15, 2003
The Final Word on Stock Options in Cost Sharing Arrangements?
Tax Management International Journal
December 1, 2003
Markers and Musings: The Proposed Section 482 Service Regulations
The Tax Executive
December 1, 2003
Transfer Pricing: New Rules for Services and Intangibles
Caplin & Drysdale
November 1, 2003
An Awakening Giant: China and the New Civil Society
The Exempt Organization Tax Review
October 1, 2003
Russia in Transition
The Exempt Organization Tax Review
September 30, 2003
Testimony of David Rosenbloom Before the U.S. Senate Committee on Finance
Committee on Finance, United States Senate
July 15, 2003
Corporate Taxation: New Consolidated Return Duplicated Loss Rules
Caplin & Drysdale
April 1, 2003
Option Wars: Upping the Ante for Cost Sharing Arrangements
Tax Management International Journal
November 8, 2002
Second First?? Transfer Pricing Issues In Secondment of Personnel
The Tax Executive
September 1, 2002
Deconstructing Section 905(c): An Examination of The Redetermination Rules After TRA 1997
Tax Notes International
April 1, 2002
Taxes Covered By §960(a)(3)
Tax Management International Journal
February 8, 2002
From the Bottom Up: Taxing the Income of Foreign Controlled Corporations
Brooklyn Journal of International Law
September 1, 2001
The IRS Reorganization: Programs and Initiatives of the New Large Case Division
Administrative Law Review, Vol. 53, No. 2
May 1, 2001
Arbitrage and Transfer Pricing Paper
Report of Proceedings of the First World Tax Conference: Taxes Without Borders
October 1, 2000
Cost-Sharing Arrangements Come of Age
Tax Management Memorandum
August 28, 2000
Transfer Pricing: A Special Report
International Tax Review Supp. 31
July 1, 2000
The UPS, Limited and Compaq Cases: Is the Tide Turning?
26 International Tax J. No. 3, 1
June 1, 2000
Mining For Nuggets in the IRS APA Report
The Tax Executive
May 1, 2000
Transfer Pricing Thoughts - North America: More Thoughts On APA Disclosure
Global Transfer Pricing
March 1, 2000
A New Way to Resolve a Factual Issue with the IRS Before Filing a Return
Caplin & Drysdale
February 21, 2000
Treaties and Interest Expense Allocation: Moving in a Natwesterly Direction
Tax Notes
January 17, 2000
Foreign Income Portfolios: U.S. Income Taxation of Foreign Corporations
Tax Management
January 1, 2000
Transfer Pricing Thoughts - North America: Thoughts on Code Sec. 482 and Rising Standards of Proof
Global Transfer Pricing
December 1, 1999
Transfer Pricing Thoughts - North America: Thoughts on Control
Global Transfer Pricing
October 1, 1999
Transfer Pricing Thoughts - North America: Thoughts on Cooperatives
Global Transfer Pricing
August 1, 1999
Transfer Pricing Thoughts - North America: Thoughts on APA Disclosure
Global Transfer Pricing
June 1, 1999
The "Ins" "Outs" "Overs" and "Unders" of the New Global Netting Rules
Tax Notes
April 26, 1999
Transfer Pricing Thoughts - North America: The Euro and the Situs of the Borrower Rule
Global Transfer Pricing
April 1, 1999
Transfer Pricing Thoughts - North America: Thoughts on Joint Ventures
Global Transfer Pricing
February 1, 1999
Navigating the Global Netting Rules: Uncertainties Abound in Interest Rate Calculation Process Under New Law
Practical U.S. /International Tax Strategies
December 10, 1998
U.S. Proposed Global Trading Regs: Preliminary Questions Regarding Application
Tax Notes International
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The Hamas Deportation: Israel's Response to Terrorism During the Middle East Peace Process
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