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Allison, Mark D.
Armitage, J. Clark
Barnes, Peter A.
Barzell, Dustin J.
Biss, Meghan R.
Borsos, Arielle M.
Brenner, Jonathan S.
Burmester, Kirsten
Caplin, 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.
Hannes, Steven P.
Hicks, Matthew C.
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.
Partain, Rachel L.
Pfeifer, Michael G.
Phillips, Todd E.
Polk, Shauna
Potter, Trevor
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.
Sharkey, Ross R.
Skillman, Richard W.
Slocombe, Walter B.
Smiley, Stafford
Stevens, Elizabeth J.
Sullivan, Sally J.
Swett III, Trevor W.
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:
Business, Investment & Transactional Tax
Alerts
Business, Investment & Transactional Tax Alert
Proposed Regulations Under Section 956
November 6, 2018
Business, Investment & Transactional Tax Alert
When Opportunity Knocks: Qualified Opportunity Zone Proposed Regulations Released
October 22, 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
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
Business, Investment & Transactional Tax Alert
Tax Plans Compared (December 2016) Corporate Tax
December 16, 2016
Tax Alert
Congress Looks to Fix New Partnership Audit Rules
December 14, 2016
Tax Alert
Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations
November 3, 2016
Business, Investment & Transactional Tax Alert
New Regulations Change Allocation of Partnership Liabilities
October 24, 2016
Tax Alert
Congress Enacts Entirely New Tax Examination and Collection Regime for Partnerships
December 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
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
Political Law Alert
Summary of New York's New Political Disclosure Rules for Nonprofits
June 21, 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
President Obama Signs Bill on Tax Cut Extensions
December 17, 2010
International Tax Alert
More and More Transfer Pricing Enforcement in Store!
August 6, 2010
Employee Benefits Alert
PPACA and Beyond – Implications for Employers Today
April 30, 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
Deductibility of Illegal Payments, Fines, and Penalties
(Book)
Bloomberg Tax 524-2nd Tax Management Portfolio
May 3, 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
EXPERT ANALYSIS: U.S. Owners of Foreign Trusts Face Increased IRS Scrutiny
Law360
June 21, 2018
IRS Launches Issue-Based Corporate Compliance Campaigns
International Law Office
February 24, 2017
IRS Launches Issue Based Corporate Compliance Campaigns
Global Tax Weekly
February 16, 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
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
Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations
International Law Office
November 25, 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
Muhammad Ali in the Time of the 'Maxi Tax'
Tax Notes
August 8, 2016
2016 Federal Tax Benefits for Hiring Qualified Veterans, National Guard Members and Reservists
(Book)
Caplin & Drysdale, Chartered
March 1, 2016
Congress Enacts New Tax Examination and Collection Regime for Partnerships
International Law Office
January 22, 2016
Applying Tobacco Tax Lessons to Sugary Drinks
University of Pennsylvania Law School, The Regulatory Review
August 27, 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 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
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
Proposed New York Tax Changes Would Affect Large and Small Businesses
International Law Office
January 30, 2015
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
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
A New Tax-and-Spend Strategy to Fight Obesity
University of Pennsylvania Law School, The Regulatory Review
January 6, 2014
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
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
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
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
Re-Membering The Nonprofit -- Uses of Members in Corporate Governance
Taxation of Exempts
December 1, 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
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 Case for Tradable Tax Credits
8 N.Y.U. J.L. & BUS. 227
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
ITPF - Georgetown University Law Center Conference on Reform of International Tax
Corporate Taxation
May 1, 2011
Putting an End to Foreign Tax Credit 'Splitting' Transactions
Corporate Taxation
March 1, 2011
President Obama's Efforts at International Tax Reform
Corporate Taxation
January 1, 2011
Advertising Liability: A Growing Risk Management Concern
Risk Management Handbook for Health Care Organizations
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
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
2009 Treaty Developments
Corporate Taxation
November 1, 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
Sound and Fury, Signifying What? The U.S. Foreign Earned Income Exclusion Debate
Tax Notes International
September 15, 2008
Conservation Easements Under Fire: A Five-Point Strategy to Defend the Deduction
Maryland Society of Accountants: The Free State Accountant
June 1, 2008
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
Pay Immediate Attention to Far-Reaching Regulations on Intercompany Services
Caplin & Drysdale
October 1, 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
Proposed Cost-Sharing Regulations Issues
Caplin & Drysdale
January 15, 2006
Revisiting the Hospital Admissions Agreement in Light of the State Charity-Care Litigation
Health Lawyers Weekly
August 26, 2005
Tax Alert
Caplin & Drysdale
June 15, 2005
Tax Alert
Caplin & Drysdale
February 1, 2005
Tsunami: NGO's Response: Now and the Future
47 Exempt Organizations Tax Review 181
February 1, 2005
The Delegation of Investment Authority by Nonprofit Corporate Boards Under UMIFA
Taxation of Exempts
January 1, 2005
Technology Transfer and the New Economy
The Exempt Organization Tax Review
January 1, 2005
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
January 1, 2005
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
December 1, 2004
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
September 1, 2004
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
August 1, 2004
News on the Transfer Pricing Front
Caplin & Drysdale
July 1, 2004
Section 6700 - IRS's Newly Found Weapon Against Professionals
Caplin & Drysdale
April 1, 2004
Corporate Tax Departments and the New Focus on Corporate Criminality
The Tax Executive
December 1, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
November 30, 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
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
October 1, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
September 1, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
August 1, 2003
Testimony of David Rosenbloom Before the U.S. Senate Committee on Finance
Committee on Finance, United States Senate
July 15, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
July 1, 2003
Codification of Economic Substance
Caplin & Drysdale Memorandum
May 7, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
May 1, 2003
Corporate Taxation: New Consolidated Return Duplicated Loss Rules
Caplin & Drysdale
April 1, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
April 1, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
March 1, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
February 1, 2003
Tax Advice After Sarbanes-Oxley
Caplin & Drysdale Tax Advice
January 24, 2003
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
December 1, 2002
Option Wars: Upping the Ante for Cost Sharing Arrangements
Tax Management International Journal
November 8, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
November 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
October 1, 2002
Accounting Methods - Which Retroactive 'Corrections' Require IRS Consent?
Tax Lawyer, Vol. 56, No. 101
September 1, 2002
Second First?? Transfer Pricing Issues In Secondment of Personnel
The Tax Executive
September 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
September 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
August 1, 2002
Letter Ruling Alert: A Blueprint for Creating a Taxable Subsidiary
The Exempt Organization Tax Review
August 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
July 1, 2002
Of Merchandise, Accruals, And Administrative Grace
Tax Notes
June 17, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
June 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
May 1, 2002
Evaluating and Managing Tax Shelter Risks
Caplin & Drysdale
April 12, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
April 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
March 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
February 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
January 1, 2002
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
December 1, 2001
Letter Ruling Alert: A New Twist in Donations of Stock Options By Disqualified Persons
The Exempt Organization Tax Review
December 1, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
November 1, 2001
Tax Accounting Montly Column
Corporate Business Taxation Monthly
October 1, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
September 1, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
July 1, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
June 1, 2001
'If Americans Really Understood The Income Tax'
Tax Notes
May 28, 2001
The IRS Reorganization: Programs and Initiatives of the New Large Case Division
Administrative Law Review, Vol. 53, No. 2
May 1, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
May 1, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
April 1, 2001
Caplin Calls for Fairness and Simplification in New Tax Legislation
Tax Notes
March 5, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
March 1, 2001
Now Is the Time to Reform the Tax Code
The Wall Street Journal
February 7, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
February 1, 2001
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
January 1, 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
The Exempt Organization Tax Review
December 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
December 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
November 1, 2000
Letter Ruling Alert: Shades of Revenue Ruling 98-15 - Ancillary Joint Ventures Between Tax-Exempt Organizations and For-Profit Entities
Exempt Organization Tax Review
November 1, 2000
Congress Requires Disclosure by Section 527 Organizations
Journal of Taxation of Exempt Organizations
November 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
October 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
September 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
August 1, 2000
Transfer Pricing: A Special Report
International Tax Review Supp. 31
July 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
July 1, 2000
The UPS, Limited and Compaq Cases: Is the Tide Turning?
26 International Tax J. No. 3, 1
June 1, 2000
Tax Workouts and Procedures During and After the IRS Restructuring
Virginia Conference on Federal Taxation
June 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
June 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
May 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
April 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
March 1, 2000
A New Way to Resolve a Factual Issue with the IRS Before Filing a Return
Caplin & Drysdale
February 21, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
February 1, 2000
Tax Accounting Monthly Column
Corporate Business Taxation Monthly
January 1, 2000
Tax Accounting Monthly Column: Bank's Loan Origination Costs Emerge As a High-Profile Issue
Corporate Business Taxation Monthly
December 1, 1999
Tax Accounting Monthly Column: Clear Reflection Principles May Work For Taxpayers Too
Corporate Business Taxation Monthly
November 1, 1999
Tax Accounting Monthly Column: IRS Wins Before the Tax Court in Norwest
Corporate Business Taxation Monthly
October 1, 1999
When Is Tax Practice 'Legal'?
Legal Times
July 5, 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