The following are selected comments by leading tax authorities on a variety of current tax issues. Extensive collections of current commentary are contained in BNA Tax Management’s news publications and specialized journals.
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U.S. Tax Enforcement Measures - An Update on Current and Proposed
Efforts,
By Edward Tanenbaum, Esq....June 2009 |
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Obama Embraces Some of the Rangel Plan and It's Deja Vu All Over
Again for U.S. Companies,
By James J. Tobin, Esq....June 2009 |
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How to Elect New Five-Year Carryback Period for 2008 Losses,
By Carla Neeley Freitag, Esq....June 2009 |
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Section 892 Controlled Commercial Entities: The USRPHC Trap,
By Kimberly S. Blanchard, Esq....June 2009 |
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The Conduit Regulations Redux, Hybrid Instruments, and LOBs,
By Kenneth J. Krupsky, Esq.....June 2009 |
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Permanent Subpart F Exemption Proposed, Certain Unresolved Issues
Remain,
By Christopher Ocasal, Esq., Michael Miles, Esq., and Carol P.
Tello, Esq.....June 2009 |
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403(b) Plan or 401(k) Plan - How to Decide,
By David E. Kenty, Esq....June 2009 |
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A “Spouse” by Any Other Name is Not Necessarily a
“Spouse”,
By Jeffrey A. Zaluda, Esq....June 2009 |
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The Exclusion of Gain on the Sale of a Principal Residence, The
New Restriction for Nonqualified Use,
By Theodore D. Peyser, Esq....June 2009 |
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IRS Says “No, Thank You” To Taxpayer’s Offer In
Compromise,
By Lisa Starczewski, Esq....June 2009 |
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Companies Should Consider Installing New Deferral Plans Before
July 1 to Maximize 2009 Compensation Deferral Opportunities,
By Louis R. Richey, J.D.,
SRVP...June 2009 |
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Reasonable Compensation - Alive and Well?,
By Stuart M. Lewis, Esq......June 2009 |
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Payments Received for Cancellation of a Lease or Distributorship
Agreement,
By James M. Kehl, CPA.....May 2009 |
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Estate of Jorgensen and Estate Inclusion of Family Limited
Partnership Interests Under Section 2036,
By Kathleen Ford Bay, Esq......May 2009 |
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Tax Court Finds Ambiguity in Tax Clause and Applies State
Apportionment Statute,
By Kathleen Ford Bay, Esq......May 2009 |
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Regulations Provide Filing Relief if Taxpayer Was in a Combat Zone
or Federally Declared Disaster Zone,
By Kathleen Ford Bay, Esq......May 2009 |
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Closing Yet Another Repatriation Loophole in
Related-Party Cross-Border Stock Transfers -- §§367/304,
By Edward Tanenbaum, Esq.....May 2009 |
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Limits on the Application of the Subpart F Branch Rules,
By Lowell D. Yoder, Esq.....May 2009 |
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Beware the Pitfalls in Shopping for Fiduciary Liability Insurance,
By Michael G. Kushner, Esq.....May 2009 |
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You Can't Deduct a Hobby Loss - That Applies to Revenue Agents
Too, of Course,
By Gerald S. Deutsch, Esq.....May 2009 |
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The §905(c) Temporary Regulations In and Out of Pooling,
By Dirk J.J. Suringa, Esq.....May 2009 |
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A “Management and Control” Test for America?,
By Philip D. Morrison, Esq.....May 2009 |
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Branching Out: The Subpart F Contract Manufacturing Regulations
v2.0,
By James J. Tobin, Esq.....April 2009 |
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FIRPTA in the 21st Century, Installment Six: FIRPTA Withholding
Where a §892 Investor Is a Partner,
By Kimberly S. Blanchard, Esq.....April 2009 |
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Should the United States Adopt a “Managed and
Controlled” Test for Offshore Investment Funds?,
By Kenneth J. Krupsky, Esq.....April 2009 |
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A Model of Reality for President Obama (and Senator Dorgan) to Use
in Evaluating Proposals for U.S. International Tax Reform,
By Herman B. Bouma, Esq.....April 2009 |
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Qualified Settlement Funds Offer Bountiful Benefits,
By Robert W. Wood....April 2009 |
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Practitioners' Forum Discussion: New Executive Compensation
Restrictions in the Stimulus Bill,
By Stuart
M. Lewis, Catherine
Creech, Keith
A. Mong, William
F. Sweetnam, Jr., and Norma
Sharara
....April 2009 |
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Using Delaware Bank Accounts and Trusts to Shield Deposits, Trust
Funds, and Trust Distributions from Creditor Claims,
By Richard W. Nenno, Esq.
....April 2009 |
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Dust Off Your HIPAA Hats: Major Changes to HIPAA Privacy and
Security Rules are on the Way,
By Julia M. Vander Weele
....April 2009 |
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Overview of Extended Carryback Period for 2008 NOLs,
By Carla Neeley Freitag, Esq.
....April 2009 |
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My Husband's A Stockholder And I'm An Employee, So Our Cafeteria
Plan Can't Be For Me,
By Gerald S. Deutsch, Esq.
....March 2009 |
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Getting My Deferred Compensation - That's My Goal - So I Want It Paid When There's A Change Of Control,
By Gerald S. Deutsch, Esq.
....March 2009 |
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New, Temporary Regulations under §954(d)(2) -- The Complex
Manufacturing Branch Rules,
By Philip D. Morrison, Esq.
....March 2009 |
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Traps for the Unwary in Loss Recapture,
By Dirk J.J. Suringa, Esq.
....March 2009 |
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Corporate Expatriation Again?,
By Edward Tanenbaum, Esq.
....March 2009 |
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Same-Country-of-Manufacture Exception to Subpart F Sales
Income,
By Lowell D. Yoder, Esq.
....March 2009 |
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IRA Charitable Rollover - He Who Giveth Can Taketh Away,
By Steven B. Gorin, Esq.
....February 2009 |
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Estate’s Settlement with Charities - Part Charitable
Deduction, Part Taxable,
By Kathleen Ford Bay, Esq.
....February 2009 |
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Estate Inclusion of FLPs, Private Annuity and Predeceasing
Spouse's Credit Shelter Trust: Choose Your Attorney Wisely,
By Kathleen Ford Bay, Esq.
....February 2009 |
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A Taxpayer’s Guide to Research Credit Documentation and the
Practical Application of Fudim, McFerrin and Eustace,
By Kendall B. Fox, Paul W. Eldridge, and Joseph F.
Maselli....February 2009 |
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Practioners' Forum Discussion: Qualified Retirement Plans --
Timing of Interim and Discretionary Amendments,
By Kyle Brown, Keith A. Mong, Anne Moran, and Gary
Quintiere.....February 2009 |
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Tax Ramifications of IFRS,
By George L. White.....February 2009 |
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Income in Respect of a Decedent - Commentary,
By Alan S. Acker, Attorney at
Law.....February 2009 |
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Tax Preparer Disclosure Penalties,
By Steven B. Gorin, Esq......February 2009 |
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More on Binding Arbitration of Tax Treaty Disputes: Issues and
Anomalies Under the Newly-Negotiated Protocol with France,
By David R. Tillinghast, Esq......February 2009 |
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A Disregarded Entity Can Be Regarded,
By Kenneth J. Krupsky, Esq......February 2009 |
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Improving Efficiency of Global Cash Utilization: Accelerated
Payments for Inventory,
By Lowell D. Yoder, Esq......February 2009 |
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Infrastructure and FIRPTA: Advanced Notice of Proposed
Rulemaking,
By Kimberly S. Blanchard, Esq......February 2009 |
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IRS Provides Cash-Strapped REITs Relief by Liberalizing Certain
Taxable Stock Dividend Rules,
By Michael Hirschfeld, Esq., Bonnie A. Barsamian, Esq., Mark D.
Grimm, Esq......February 2009 |
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Structuring Partner Nonrecourse Advances to Partnerships in Light
of the Proposed Cancellation of Indebtedness Regulations,
By John C. McCoy, Esq......February 2009 |
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Independent Contractor or Employee - There Are Tests To Determine
What Your Worker Will Be,
By Gerald S. Deutsch, Esq.....February 2009 |
