Media Mentions
2008
Elizabeth Lewis was quoted in the September issue of Chicago Lawyer on the balancing act of affording law school. "If you are sure that law is something that you want to do, and you know it's something you will enjoy doing, then my best advice is to just pursue it and pursue whatever area of law you enjoy most," Ms. Lewis said. "Enjoying what you do is very important."
Andrea Kramer was quoted September 26 on guardian.co.uk about how U.S. regulators are looking into credit derivatives as they investigate market manipulation, and some lawyers believe the government is looking at whether traders have used the products to help push banks closer to insolvency. "You can affect investors' perception of the company, and affect the company's credit-worthiness," Ms. Kramer said.
Andrea S. Kramer, Financial Products, Trading & Derivatives, Tax
Art Rosen was quoted in the August 31 issue of Sales & Use Tax Monitor about a new law requiring that online retailers collect sales tax on purchases made by state residents if they have any affiliates - including Web affiliates - with physical presence in New York. "I think that you'll find that the Assembly in New York is much more pro-revenue than the Senate was," said Mr. Rosen.
Arthur R. Rosen, State & Local Tax, Tax
Roy Crawford was quoted in the August 15 issue of State Income Tax Monitor about how a court threw out California authorities' seemingly convoluted argument for disallowing an insurance company's deductions for management fees. Mercury General Corp. was reimbursed by two insurance subsidiaries for providing certain management services. The Franchise Tax Board balked at allowing a deduction for expenses under a "but-for" test. "That test says that if a parent has an expense and somehow expects that the subsidiary will pay a dividend, part of the expense will be disallowed because they'll get a dividend someday," said Mr. Crawford.
Roy E. Crawford, State & Local Tax, Tax
Robin Greenhouse was quoted in the August 11 issue of Tax Analysts on the recent district court ruling that requires a company to release to the government documents it claimed were subject to nondisclosure by the tax practitioner privilege. "I've been concerned about the scope of the tax practitioner privilege for some time and in particular the legal implications of a ruling in a summons enforcement case that the transaction at issue is a tax shelter for purposes of the tax shelter exception under section 7525," Ms. Greenhouse said.
Robin L. Greenhouse, Tax, Tax Controversy
Robin Greenhouse was mentioned in the August 7 issue of the Daily Tax Report for being part of the team representing Wal-Mart Stores, Inc. The North Carolina Court of Appeals ordered in camera review of tax documents related to consulting services Ernst & Young provided to assist Wal-Mart Stores, Inc. in implementing tax shelters to see if any of the materials is protected from a DOR summons.
Robin L. Greenhouse, Tax, Tax Controversy
Robin Greenhouse was quoted in the July 28 issue of The National Law Journal on how the attorney work-product fight is now taking shape in the federal courts, most recently in the Textron and Regions cases. Ms. Greenhouse commented that the work-product controversy may be "something of a perfect storm," triggered by post-Enron demands for greater financial disclosures.
Robin L. Greenhouse, Tax, Tax Controversy
Bill Goldman was quoted in the July 14 edition of The Daily Record on Dang Chien Thang's, a native of Vietnam, first visit to the United States earlier this month. "His participation has been invaluable," said Goldman, a Global Community Service Foundation board member who, as chairman of the program committee, works closely with Thang.
William L. Goldman PC, Tax, Tax Controversy
Bob Dilworth was mentioned in the June 25 Congressional Documents and Publications, the June 26 issues of FNS Daybook and The Frontrunner, and the June 27 issues of US Fed News andWebCPA about being a witness at the Senate Finance Committee's hearing conducted "to examine the foundation of international tax reform, focusing on worldwide, territorial, and related corporate tax issues," according to a committee notice published in the Congressional Record.
Robert H. Dilworth, International Tax, Tax
Blake Rubin was quoted in the May 22 issue of Federal Tax Weekly in an article regarding proposed partnership allocation regs. Blake commented that the proposed regs further strengthen the anti-abuse rules. "The look-through concept certainly make sense," Mr. Rubin said.
Blake D. Rubin, Tax, Tax Controversy
Blake Rubin was quoted in the May 22 issue of Federal Tax Weekly in an article regarding how final regs apply substantial economic effect rules to indirect partners. Mr. Rubin commented that the final regs contain minor "tweaks" to the regs proposed in 2005 and that the existing regs "already [involve] burden."
Blake D. Rubin, Tax, Tax Controversy
Robin Greenhouse was quoted in the May 22 issue of CCH Federal Tax Weekly on Regions Financial Corp. et al. v. United States. Ms. Greenhouse explained that both Regions and Textron (a much-heralded IRS loss on privilege that is now on appeal in the First Circuit) found that it would be unfair for the government to obtain these documents. "It's not helping the IRS develop the facts or develop issues. It's really just telling the IRS--This is how the taxpayer values the case." Ms. Greenhouse further pointed out that the government would be just as adamant about protecting its own work product documents as well.
Robin L. Greenhouse, Tax, Tax Controversy
Art Rosen was quoted in the May 15 issue of Sales & Use Tax Monitor in an article regarding the complexity of sales tax compliance in the state of New York. "The rules are so arcane," Mr. Rosen said. "It makes it so difficult. In New York, a Twix bar is taxable if it's on the shelf with candy and exempt if it's on the shelf with cookies. Little marshmallows are used for cooking and therefore exempt, but big marshmallows are considered candy and therefore taxable," he added.
Arthur R. Rosen, State & Local Tax, Tax
Robin Greenhouse was quoted in the May 15 issue of CCH Federal Tax Weekly on Regions Financial Corp. et al. v. United States. Ms. Greenhouse pointed put that, while application of the work product doctrine in Textron and Regions was the same, the facts were slightly different in what the IRS was seeking from the taxpayer. Ms. Greenhouse stated, "In Textron, they were looking more at the actual workpapers themselves...items indicating the percentage of likelihood of success...this is looking at the actual tax opinion that was prepared ... Regions is really looking at the opinion; Textron is looking at: Now what do they do based on their legal opinions?"
Robin L. Greenhouse, Tax, Tax Controversy
Art Rosen was quoted in the May 15 issue of Sales & Use Tax Monitor in an article regarding the case of Amazon.com Inc./Seattle vs. the New York Supreme Court and its potentially huge implications for companies making sales into states where they lack a physical presence. "So far, no state has enacted anything close to what this does in New York," Mr. Rosen said. "There are several states that will impose nexus on a company that has a brick-and-mortar affiliate in a state, but that's as far as it goes," he added.
Arthur R. Rosen, State & Local Tax, Tax
Robin Greenhouse was quoted in the May 13 issue of Tax Notes on Regions Financial Corp. et al. v. United States. Ms. Greenhouse said the opinion was important, "Because it provides work product protection for a tax opinion that is prepared to evaluate the litigation risk of a particular transaction, even if it is understood at the time of preparation that such opinion will likely be disclosed to the independent auditor."
Robin L. Greenhouse, Tax, Tax Controversy
Blake Rubin and Andrea Whiteway were mentioned in the May 5 issue of Legal Times about how their hiring highly contributed to the inclusion of the Firm's Washington, D.C., office in the "2008 D.C. 20" rankings.
Blake D. Rubin, Andrea Macintosh Whiteway, Real Estate - Tax, Tax
Tom Jones was mentioned in the April issue of Chicago Lawyer for receiving the Captive Insurance Companies Association's 2008 Distinguished Service Award.
Thomas M. Jones PC, Captive Insurance and Reinsurance, Tax
Tom Jones was mentioned in the May issue of The Risk Retention Reporter and the April issue of American Agent & Broker for receiving the Captive Insurance Companies Association's 2008 Distinguished Service Award.
Thomas M. Jones PC, Captive Insurance and Reinsurance, Tax
Tom Jones was quoted in the April issue of Rough Notes about how the IRS reversed its proposal concerning the taxation of captives. "The consolidated tax return area of the IRS has a huge amount of authority to promulgate regulations," Mr. Jones said. "Congress has given the Consolidated Returns Group the authority to write 'legislative regulations' as contrasted with 'interruptive regulations' that other code areas are limited to," he added.
Thomas M. Jones PC, Captive Insurance and Reinsurance, Tax
Jean Pawlow was mentioned in the April 10 issue of Tax Management Transfer Pricing Report for her presentation at the TEI 58th Midyear Conference. Ms. Pawlow said taxpayer comments about Tier 1 audits have made the process sound like buying a car in that the audit team seems to want to help but must periodically consult "someone in the back" who has decision-making power. Ms. Pawlow also said the teams, "Seem to keep telling us we have to go to Appeals."
Jean A. Pawlow, Tax, Tax Controversy
Jean Pawlow was mentioned in the April 8 issue of TaxAnalysts for her presentation at the TEI 58th Midyear Conference. Among other questions, Ms. Pawlow asked fellow panelist Patricia Chaback, industry director for LMSB's communications, technology and media division in Oakland, Calif., if it is appropriate for Appeals to be involved in the Industry Management Team (IMT). Chaback replied that even though an Appeals representative may be present on the team, Appeals maintains the "utmost level of independence" throughout the issue process and is subject to the ex parte rules.
Jean A. Pawlow, Tax, Tax Controversy
Tom Jones was quoted in the March 2008 issue of Vermont Business Magazine about how the IRS withdrew the proposed regulation that would have prevented captive insurance companies based in the Unites States from claiming tax deductions for money set aside to cover future claims and losses. Under the existing tax code, Mr. Jones said, "We do have a level playing field." The proposed IRS regulation, "Will have the possibility of tilting the field," he said, toward the offshore domiciles.
Thomas M. Jones PC, Captive Insurance and Reinsurance, Tax
Tom Jones was mentioned in the March 27 issue of Risk & Insurance for receiving the Captive Insurance Companies Association's 2008 Distinguished Service Award.
Thomas M. Jones PC, Captive Insurance and Reinsurance, Tax
Tom Jones was quoted in the March 17 issue of Business Insurance about how the IRS reaffirmed its long-held position that excise taxes on insurance and reinsurance purchased from foreign insurers and reinsurers apply each time a risk is ceded, but also has offered an amnesty period to encourage compliance. "How will the information flow work, particularly if a U.S. risk is sliced and diced in co-mingled excess-of-loss treaties...lots of administrative problems," said Mr. Jones.
Thomas M. Jones PC, Captive Insurance and Reinsurance, Tax
Art Rosen was quoted in the March 15 issue of State Income Tax Monitor about how a guilty plea and an agreement to pay restitution over tax fraud will not always pull you off the state's hook. "A lot of people get blindsided by this," said Mr. Rosen. "Unless the taxation department signs off on the plea agreement, they are not prevented from seeking past due tax, penalties and interest. The attorney general can offer a deal, but the tax department doesn't have to honor it."
Arthur R. Rosen, State & Local Tax, Tax
Art Rosen was quoted in the March 15 issue of Sales & Use Tax Monitor about how company tax pros should not be surprised when an auditor turns to an alternative methodology or when a tax appeals panel upholds that back-up approach. "It's been going on pretty regularly over the last 15 years," said Mr. Rosen.
Arthur R. Rosen, State & Local Tax, Tax
Tom Jones was mentioned in the March 14 issue of Chicago Daily Law Bulletin for going to the University of Illinois in Champaign to address the students in the class called "Law 794: International Business Organizations: The Cayman Islands."
Thomas M. Jones PC, Captive Insurance and Reinsurance, Tax
Art Rosen was quoted in the February 29 issue of Sales & Use Tax Monitor about how the New York Taxation Division has undertaken some creative approaches to calculate a business' taxable sales, when that taxpayer lacks the proper records to satisfy the auditor. "The state can pick any method that they want to on an audit, when there are insufficient records," pointed out Mr. Rosen. "The taxpayer usually can't prove the method was unreasonable if the records are not there."
Arthur R. Rosen, State & Local Tax, Tax
Tom Jones was quoted in the February 25 issue of the National Underwriter about how the IRS dropped its proposed captive tax proposal. Mr. Jones responded that the news is "gratifying -- a once-in-a-career event, maybe." He added that "apparently, they took the [industry's] comments seriously."
Thomas M. Jones PC, Captive Insurance and Reinsurance, Tax
Tom Jones was quoted in the February 25 issue of Business Insurance about how the captive insurance industry is savoring a huge victory in last week's Internal Revenue Service decision to withdraw a proposed rule that would have stripped hundreds of captives of a key tax advantage, but other regulatory threats remain. "It really was a three-pronged approach," said Mr. Jones.
Thomas M. Jones PC, Captive Insurance and Reinsurance, Tax
Tom Jones was mentioned in the February 22 issue of Chicago Daily Law Bulletin for receiving the Captive Insurance Companies Association's 2008 Distinguished Service Award.
Thomas M. Jones PC, Captive Insurance and Reinsurance, Tax
Art Rosen was quoted in the February 5 issue of State Income Tax Monitor about how the U.S. Supreme Court won't hear arguments from two affiliated limousine companies and their owner who say New York authorities persecuted them with a sales and use tax assessment. "You need to be able to prove that there was malicious intent," said Mr. Rosen. "There are people in the department of taxation that do tend to probably act in that way, but it's difficult to prove," he added.
Arthur R. Rosen, State & Local Tax, Tax
Robin Greenhouse was referenced in the January issue of The Tax Adviser about FIN 48 compliance. "Effective tax rate reconciliation workpapers, whether created by the taxpayer or the auditor, are part of the tax accrual workpapers" and are thus subject to restraint, Ms. Greenhouse was cited.
Robin L. Greenhouse, Tax, Tax Controversy
Tom Jones was quoted in the January 16 issue of Business Insurance about how the IRS has provided examples of situations in which employers can and cannot take tax deductions for premiums paid in cell captive insurance arrangements. "Cells are attractive to businesses that don't want to go through the time and expense of setting up a captive insurer," said Mr. Jones.
Thomas M. Jones PC, Captive Insurance and Reinsurance, Tax
Greg Palmer was quoted in the January 14 issue of Crain's Chicago Business about how the Chicago Sun-Times may be faced with a tax bill for as much as $530 million. "Most companies faced with large tax liabilities file a protest, which typically triggers years of wrangling with the IRS appeals division," Mr. Palmer said. "It's likely to be a matter of years before this is resolved, given the magnitude of the proposed adjustments," he added.
Gregory G. Palmer, Tax, Tax Controversy
Michael Fayhee and John Tamisiea were quoted in the January 2008 issue of the Chicago Lawyer regarding their representation of The Genlyte Group, Inc. in its definitive merger agreement with Phillips Holding USA.
Michael R. Fayhee, John P. Tamisiea, Corporate, Tax
Art Rosen was quoted in the January 1 issue of Financial Services Law360 regarding the Department of Revenue of Kentucky et al. v. George W. Davis et al. "It might be seen as a real undue burden on the states if it were to apply retroactively," Mr. Rosen said. "If that were to happen, Congress would probably take action immediately to address it in some way. Either way, Congress would have the ability to address the municipal bond taxation issue. But Congress can decide not to get involved at all, thus allowing the Supreme Court's ruling to stand," he added.
2007
The Washingtonian released its fifth list of "Big Guns" in the December 2007 issue. The Washingtonian selects "Big Guns" based on peer recommendations and follow-up interviews. The following McDermott lawyers were named "Big Guns": Bobby R. Burchfield, Joel M. Freed, Abbe D. Lowell and Blake D. Rubin.
Bobby R. Burchfield, Joel M. Freed, Abbe D. Lowell, Blake D. Rubin, Intellectual Property, Media & Technology, Tax, Trial
Art Rosen was quoted in the December 15 issue of Sales & Use Tax Monitor about how businesses are well advised not to rely too heavily on their postage meters as acceptable proof of timely delivery in tax disputes. "That's why I always send letters for that by registered mail," said Mr. Rosen. "Otherwise, it comes down to credibility. You need a rule like this, or people would flout the statutes of limitations law," he added.
John Lutz was quoted in the December 10 issue of The Bond Buyer about how the turbulence blowing global financial markets askew has not slowed the creation of tender-option bond trusts, according to new data compiled from the major credit rating agencies. "You're certainly going to see residual owners react to the availability of liquidity by moving trusts from one program to another," Mr. Lutz said.
John T. Lutz, Finance & Banking, Tax
Tom Jones was quoted in the November 19 issue of Business Insurance on how Bermuda's regulatory regime is driving innovative insurance ideas. Unlike the crazy-quilt of state regulation that prevails in the United States, the Bermuda regime has always emphasized efficiency and sought to accommodate the needs of sophisticated policyholders, while also supervising insurer licensing and solvency, those familiar with the domicile say. "In the United States, Vermont has been particularly responsive to captive owners, amending captive laws to allow reciprocals, not-for-profit companies and other variations on the captive form," Mr. Jones said.
Blake Rubin was quoted in the November 9 issue of Tax Analysts about how the Treasury and IRS officials at a November 7 District of Columbia Bar Taxation Section program said they are continuing to analyze the complex theories behind contributions of property to partnerships and develop a grounded approach in the accompanying tax rules. "An implied result of the approach taken by the government is a construct of lawyers," said Mr. Rubin. "There remain(s) a lack of guidance for secondary and tertiary issues under section 704(c)(1)(A)," he added.
Tom Jones was mentioned in the October 22 issue of National Underwriter for chairing the task force reviewing the proposed IRS regulations and developing recommendations to the CICA board for an industry response.
Tom Jones was quoted in the October 15 issue of Business Insurance about how the captive insurance industry is gearing up to fight proposed Internal Revenue Service rules that would strip a key tax break now enjoyed by hundreds of captives. "Through the proposed rules, the IRS is attempting to override judicial decisions as well as its own prior rulings," said Mr. Jones.
Art Rosen was quoted in the October 15 issue of Sales & Use Tax Monitor on how some states continue to give their auditors considerable wiggle room in deciding when an observation test is justified during a sales and use tax audit. "We've seen a lot of them over the last 10 years," said Mr. Rosen.
Peter Faber was quoted in the October 10 issue of the New York Sun about how Congress is backing off legislation to raise taxes that would hit the New York's private equity industry, but now London has announced plans to do just that. "Anything that arguably makes London a less attractive place to do private equity deals or anything else benefits New York because we are in direct competition," Mr. Faber said.
Blake Rubin, Andrea Whiteway and Jon Finkelstein were mentioned in the October 1 issue of International Tax Review for joining McDermott’s Tax Department in Washington, D.C.
Jon Finkelstein, Blake D. Rubin, Andrea Macintosh Whiteway, Tax
Lydia Kelley was quoted in the September 28 issue of the Boston Business Journal about how more law school graduates are accepting jobs in other industries rather than joining law firms. "We do see biotechs and investment banks looking at law students, but you also have law students looking," said Ms. Kelley. "You've got a generation of law students who want to look at all their options, whereas as recently as a few years ago many students would be looking primarily at law firms," she added.
Art Rosen was quoted in the September 15 edition of Sales & Use Tax Monitor regarding a New York-based manufacturer being held liable for a sales and use tax audit assessment based on available records. Upon a New York state audit, the manufacturer claimed necessary documents could not be produced once they had been turned over to the Bankruptcy Court. The Tax Appeals Division upheld an audit methodology based on the best records available. "This situation comes up all the time," commented Mr. Rosen. "Clients tell us they can't get access to the records because they're tied up in court. I think it's unfair to hold a company to a certain level of proof when they can't prove something because they don't have access to the documents," he said.
Arthur R. Rosen, Tax, Tax Controversy
Blake Rubin, Andrea Whiteway and Jon Finkelstein were mentioned in the September 5 issue of The Washington Business Journal for joining McDermott’s Tax Department in Washington, D.C.
Jon Finkelstein, Blake D. Rubin, Andrea Macintosh Whiteway, Tax
Blake Rubin, Andrea Whiteway and Jon Finkelstein were mentioned in the September 4 issue of The Wall Street Journal and the September 3 issue of The Washington Post for joining McDermott’s Tax Department in Washington, D.C.
Jon Finkelstein, Blake D. Rubin, Andrea Macintosh Whiteway, Tax
Blake Rubin, Andrea Whiteway and Jon Finkelstein were mentioned in the September 2 issue of the Tax Grotto for joining McDermott’s Tax Department in Washington, D.C.
Jon Finkelstein, Blake D. Rubin, Andrea Macintosh Whiteway, Tax
Dirk Pohl was quoted in the August issue of Juve Rechtsmarkt regarding the announcement of the new partner Peter Bauschatz.
Art Rosen was quoted in the August 31 edition of Sales & Use Tax Monitor regarding a recent ruling by the Tax Appeals Division in New York that refused to make an employee liable for a company’s unpaid sales taxes. "Just because you sign documents and have that authority doesn’t mean you’ve got the authority to be a responsible party," stated Mr. Rosen.
Arthur R. Rosen, Tax, Tax Controversy
Robin Greenhouse was quoted in an August 31 article published by Tax Analysts regarding the district court decision in United States v. Textron. The district court refused to enforce an IRS summons for the tax accrual workpapers of Textron Inc. and its subsidiaries, finding that the workpapers are protected by the work product privilege and that Textron didn’t waive that privilege by disclosing the documents to Ernst & Young, its independent auditor. Ms. Greenhouse said Textron was correctly decided and a significant win for taxpayers. “The long and the short of it is an issue of fairness. The court may have been influenced by fairness. That’s what really shows up on the last two pages of the opinion,” stated Ms. Greenhouse.
Robin L. Greenhouse, Tax, Tax Controversy
Lydia Kelley was quoted in the August 27 issue of The National Law Journal about how law firms continue to experiment with technology and new summer associate program models to enhance recruitment. According to Ms. Kelley McDermott hones its message and selling points through firmwide interview training for all lawyers. "It's making sure our attorneys understand the importance of being aware of the headline case in D.C. or the pro bono award in the Silicon Valley," Ms. Kelley said.
Blake Rubin, Andrea Whiteway and Jon Finkelstein were mentioned in the August 23 issue of Legal Times and the August 24 edition of The Daily Deal for joining McDermott’s Tax Department in Washington, D.C.
Jon Finkelstein, Blake D. Rubin, Andrea Macintosh Whiteway, Tax
Art Rosen was quoted in the August 15 edition of Sales & Use Tax Monitor on how New York state's fraud penalty against a corporation for uncollected sales tax was voided, and then the penalty against the individual responsible officer was. "This one's pretty clear. It says if there's a conciliation notice saying the company is not guilty of fraud, then the fraud charges are removed vis-à-vis the responsible person," Mr. Rosen said.
Arthur R. Rosen, State & Local Tax, Tax
Rick Mitchell, Uwe Goetker, Norbert Schulte, Dirk Pohl, Volker Teigelkotter, Oliver Köster, Georgia Quenby, Loyala de Silva, Kate Geraghty, Stuart Sinclair and Razia Begum were mentioned in the August issue of Juve Rechtsmarkt regarding the advise of the owner of the Group, Dr Alfred Schefenacker on all aspects of the consensual restructuring of the Schefenacker Group.
Loyala de Silva, Kate Geraghty, Uwe Goetker, Richard Mitchell, Dirk Pohl, Georgia Quenby, Norbert Schulte, Stuart Sinclair, Volker Teigelkötter, Corporate, Employee Benefits & Pensions, Germany, London, Tax
Uwe Goetker, Norbert Schulte, Rick Mitchell, Georgia Quenby, Dirk Pohl and Volker Teigelkotter were mentioned in the July 11 issue of Börsenzeitung regarding the representation of Dr. Alfred Schefenacker, owner of the Schefenacker Group, in connection with the Group's comprehensive financial and operational restructuring.
Uwe Goetker, Richard Mitchell, Dirk Pohl, Georgia Quenby, Norbert Schulte, Volker Teigelkötter, Corporate, Employee Benefits & Pensions, Germany, London, Tax
Tom Jones was mentioned in the June 14 issue of National Underwriter Online News Service about speaking at the online seminar presented by Chicago-based insurance broker Aon Corporation titled “Evaluating and Developing an Effective Captive Strategy.”
Thomas M. Jones PC, Captive Insurance and Reinsurance, Health Care Industry Captive Insurance, Tax
Andrea S. Kramer was featured in the June 2007 issue of Lawdragon magazine in the "Top 500 Leading Dealmakers" ranking. Lawdragon creates its guides to the best lawyers in the United States through a unique combination of online balloting and independent research.
Tom Sykes was quoted in the June 1 issue of The Trusted Professional about the recent U.S. Supreme Court decision in KSR International Co. v. Teleflex, Inc. on the patentability of tax strategies. Mr. Sykes noted that the decision "is good news for tax practitioners who are concerned about the emergence of tax strategy patents."
Thomas D. Sykes, Tax, Tax Controversy
Andrea Kramer was mentioned in the June issue of the Chicago Lawyer for receiving the first Founders Award from The Women's Treatment Center.
Art Rosen was quoted in the May 31 issue of Sales & Use Tax Monitor about how auditors will switch their methods when they suspect that a business may have fudged their taxable sales figure in hopes of retaining more funds. "An auditor frequently uses a purchase mark-up methodology to assess tax when a company's sales don't jibe with the owner's books and records," said Mr. Rosen.
Arthur R. Rosen, Tax, Tax Controversy
Art Rosen was quoted in the May 31 issue of State Income Tax Monitor on whether a company’s monetary judgment in a lawsuit should be taxable as business income. "If it's a normal lawsuit it's probably not going to be taxable. But if it's greenmail or a major copyright infringement, it would probably qualify as income.” Mr. Rosen said.
Arthur R. Rosen, Tax, Tax Controversy
Tom Jones was mentioned in the May 30 issue of National Underwriters about speaking at the CIC-DC’s “Solving Health Care Liability Risks Through Alternative Risk Transfer” session on June 5.
Peter Faber was quoted in the May 29 issue of Dow Jones Newswires about several steps to guard against being doubly taxed if you live in one state but spend a lot of time relaxing in another. "There are an awful lot of people who play games with this, who have a winter place in Florida and spend only four months down there," said Mr. Faber.
Peter L. Faber, Tax, Tax Controversy, Tax Exemption
Andrea Kramer was named among in The National Law Journal 50 Most Influential Women Lawyers in America published on May 28.
Andrea S. Kramer, Derivatives, Structured Finance and Financial Products, Tax
Peter Faber was quoted on May 22 on The Wall Street Journal Online about the challenge by a Kentucky couple to a Kentucky state law that exempts interest on bonds issued within Kentucky while taxing interest on most non-Kentucky municipal bonds. Most states that have a state income tax, such as New York and California, have similar laws. "This is an issue of great national importance that involves many investors in state and local bonds," said Mr. Faber.
Peter L. Faber, State & Local Tax, Tax, Tax Controversy, Tax Exempt Bonds
Fred Ackerson was mentioned in the May 14 edition of the Crain’s Chicago Business about recently joining McDermott’s Tax Department in Chicago.
Fred M. Ackerson, State & Local Tax, Tax
Fred Ackerson was mentioned in the May 8 edition of the Daily Deal/The Deal and the May 10 edition of the Chicago Daily Law Bulletin about recently joining McDermott’s Tax Department in Chicago.
Fred M. Ackerson, State & Local Tax, Tax
Lydia R.B. Kelley was quoted in the May issue of the Chicago Lawyer in an article about how to best recruit and keep talented new associates. "Candidates must possess the skills to attract work and clients outside of the firm and have the ability to seek projects and experience within the firm," Ms. Kelley said.
Lydia R.B. Kelley, Tax, Tax - Acquisitions & Restructurings
Art Rosen was quoted in the April 30 issue of Sales & Use Tax Monitor about the tangible version of a product is exempt from sales tax while the electronic version is taxable. "I read that opinion and thought, 'Whoa, you don't see that every day,'" Mr. Rosen said.
Arthur R. Rosen, State & Local Tax, Tax, Tax Controversy
Art Rosen was quoted in the April 15 issue of Sales & Use Tax Monitor about how the Taxation and Finance Department ruled that an out-of-state seller of service contracts established sufficient nexus in New York to have to register and collect sales and use tax. "New York, like California, has been a physical presence state when it comes to determining nexus," Mr. Rosen said.
Arthur R. Rosen, State & Local Tax, Tax
Jean Pawlow and Elizabeth Erickson were mentioned April 6 in the Blog of the Legal Times for joining McDermott’s tax practice.
Elizabeth Erickson, Jean A. Pawlow, Tax, Tax Controversy
Mary Lee Turk was mentioned in the April 4 edition ofPrism Insight: Trust & Estates Online Exclusive for her report she had written that discusses the issues, history and potential problems involved with patents for tax strategies.
Mary Lee Turk, Intellectual Property, Media & Technology, Private Client, Tax
Peter Faber was quoted in the March 27 edition of The New York Times in an article about the New York governor's office closing "loopholes" that corporations use to reduce their tax bills in order to balance the state budget, although many business leaders say there are no loopholes to close.
Peter L. Faber, State & Local Tax, Tax
Peter Faber was quoted in the March 27 edition of The New York Times article about the New York governor’s office closing "loopholes" that corporations use to reduce their tax bills in order to balance the state budget. However, many business leaders say there are no loopholes to close. "All the way back to 1945, New York has held out its refusal to adopt a unitary tax system as an inducement to headquarters companies to locate here," Mr. Faber said. With this change, he added, "you could have a company with an out-of-state subsidiary that has no operations in New York but sells to New York customers, and that company could be dragged into a New York tax return."
Tom Jones was quoted in the March 12 issue of Business Insurance in an article detailing the recent legislative activity on captive insurance laws around the globe. "Most of the domiciles are tweaking their statues, rather than changing them," Mr. Jones said.
Thomas M. Jones PC, Insurance, Insurance Companies and Products Tax, Tax
Robert H. Dilworth was mentioned in The Wall Street Journal on February 28 for joining McDermott as a partner in the Tax Department in the Washington, D.C. office.
Ralph DeJong was quoted in the February 26 issue of BNA, Inc. Daily Tax Report in an article regarding the IRS's 2006 Form 990. "What it leaves open is the very cumbersome and intrusive process of determining from directors and independent contractors who they may be related to, what business interests they may have outside the organizations they serve on, when they or their family members may be related through trusts, partnerships, or business corporations, and the extent of those relationships," Mr. DeJong said.
Ralph E. DeJong, Employee Benefits & Pensions, Tax
Keith Staats was quoted in the February 15 issue of Sales & Use Tax Monitor in an article concerning the compliance and legal difficulties of the tax holiday proposals of Chicago mayoral candidate Dorothy Brown. The holidays would apply only to certain areas and certain businesses resulting in complicated enforcement and questionable constitutionality. "You can't implement a sales tax holiday without enabling legislation," Mr. Staats said.
Keith Staats, State & Local Tax, Tax
Art Rosen was quoted in the February 15 and February 28 issues of State Income Tax Monitor on the $1 billion in business and personal tax cuts including in New York mayor Michael Bloomberg's preliminary city budget. "Even with the increase, the per-partner deduction is out of touch with reality," Mr. Rosen said. "There should be something related to compensation levels rather than just a small flat amount for the deduction."
Arthur R. Rosen, State & Local Tax, Tax
Michael Peregrine was quoted in the February 6 issue of TaxAnalysts in an article discussing a list that was prepared by the IRS of preliminary guidelines designed to help charity boards improve their oversight of charities. "Charity boards should take a good look at the guidelines. I wouldn't just blow these off as insignificant or as breaking no new ground. The guidelines make a couple of important points," Mr. Peregrine said.
Michael W. Peregrine, Health, Tax, Tax Exemption
Tom Jones was quoted in the February 4 issue of the Hartford Courant in an article on the expansion of "captive" insurance companies in Connecticut. "Captives are not a 'tax dodge,' but if they meet certain IRS qualifications, they can take a tax deduction on the money the put into reserves for claims," Mr. Jones said.
Thomas M. Jones PC, Insurance, Insurance Companies and Products Tax, Tax
Art Rosen was quoted in the January 31 issue of the Sales & Use Tax Monitor and in the February issue of Tax Incentives Alert in an article about sales tax exemptions on property capital improvements in New York. “New York has always been very mechanical in the way they apply the capital improvement part of the sales tax law. They look at the letter of the law rather than the merits of an individual case,” Mr. Rosen said.
Arthur R. Rosen, State & Local Tax, Tax
Art Rosen was mentioned in the February issue of the Metropolitan Corporate Counsel as one of the overall planning chairs for the upcoming New York State Bar Association’s Eleventh Annual New York State and City Tax Institute.
Arthur R. Rosen, State & Local Tax, Tax
Art Rosen was quoted in the February issue of Managing Accounts Payable for a speech he recently gave at NYU, where he stated that the atmosphere of the new Congress was more friendly to the passage of the Streamlined Sales Tax.
Arthur R. Rosen, State & Local Tax, Tax
Art Rosen was mentioned in a January 30 press release from The Global Knowledge Congress as a panelist in their upcoming "48 Fin: Practical Recommendations" teleconference to be held on March 8. The teleconference features a panel of experts aimed at clarifying the recently implemented 48 FIN tax regulations and providing recommendations for the organizations affected.
Mario Martinelli, Andrea Tempestini and Carlo Paolella were mentioned in the January 20 issue of Italia Oggi as new tax partners in our Rome office.
Mario Martinelli, Carlo Maria Paolella, Andrea Tempestini, Italy, Tax, Tax - Italy
Peter Nias was listed on The Times Law Panel of 100 lawyers published on January 16. The Law Panel is set to boost the legal coverage in the paper and serve as a sounding board for issues and the centerpiece of The Times' online law section.
Peter M.W. Nias, London, Tax, Tax - London
Art Rosen was quoted in the January 15 issue of Sales & Use Tax Monitor citing the MTC 95-1 bulletin as the interpretation used by New York tax authorities to apply sales tax to vendors using in-state, third-party repair services for service contracts purchased online.
Arthur R. Rosen, State & Local Tax, Tax
Carlo Paolella, Mario Martinelli and Andrea Tempestini were mentioned in the January 5 issue of Il Mondo in regard to their move to McDermott from Trivoli & Associates.
Mario Martinelli, Carlo Maria Paolella, Andrea Tempestini, Italy, Tax, Tax - Italy
Carlo Paolella, Mario Martinelli and Andrea Tempestini were mentioned in the January 4 issue of Economy in regard to their move to McDermott from Trivoli & Associates.
Mario Martinelli, Carlo Maria Paolella, Andrea Tempestini, Italy, Tax, Tax - Italy
Jean Pawlow and Elizabeth Erickson were mentioned the January 1 issue of International Tax Review and the January 9 issue of The Deal for joining McDermott as partners in the Tax Department based in its Washington, D.C. office.
Elizabeth Erickson, Jean A. Pawlow, Tax
Thomas Giegerich, Mario Martinelli, Andrea Tempestini and Carlo Paolella were mentioned in the January 1 issue of The National Law Journal for joining McDermott's Tax Department.
Thomas W. Giegerich, Mario Martinelli, Carlo Maria Paolella, Andrea Tempestini, International Tax, Italy, Tax
2006
Carlo Paolella, Mario Martinelli and Andrea Tempestini were mentioned in the December 18 issues of Daily Deal and The Lawyer about joining McDermott's Italian tax practice.
Thomas Giegerich was mentioned in the December 15 issue of The New York Times for joining McDermott as a partner in the New York office and the head of the office's federal tax practice.
Art Rosen was quoted in the November 30 issue of State Income Tax Monitor on West Virginia Supreme Court of Appeals' decision to uphold economic nexus on MBNA America Bank's marketing. According to Mr. Rosen, the decision underscores "the definite need for federal legislation like H.R. 1956," which would order a physical presence nexus standard for state business activity taxes.
Arthur R. Rosen, State & Local Tax, Tax
Art Rosen was quoted in the November 15 issue of Sales & Use Tax Monitor in an article on the appointment of Barbara G. Billet as acting commissioner of the New York Taxation and Finance Department following the resignation last month of Andrew S. Eristoff. "One of the things I've learned in many years in the business is that the attitude of the person at the top of the agency will trickle down to the line people eventually," Mr. Rosen said.
Arthur R. Rosen, State & Local Tax, Tax
David Noren was quoted in the November 1 issue of Euromoney Institutional Investor in an article concerning the need for corporate tax reform and the snails' pace at which it had progressed. "There doesn't seem to be a huge push to get anything done quickly…It's hard to be too optimistic about tax reform. I don't think anyone thinks the whole process is dead but it certainly hasn't got anywhere in the past year," Mr. Noren said.
On October 25 on AccountingWEB.com, an article on the patenting of tax strategies references the article, "Whose Tax Law Is It?" by Paul Devinsky, John Fuisz and Thomas Sykes published in the October 16 issue of Legal Times. The article references the authors' statement that tax patents could lead to unequal treatment under the tax code, becoming "government issued barbed wire" for some taxpayers.
Paul Devinsky, John R. Fuisz, Thomas D. Sykes, Intellectual Property, Media & Technology, Tax
On Friday, October 20, the front page of The New York Times business section included an article on the patenting of tax strategies with a significant reference to the article, "Whose Tax Law Is It?" by Paul Devinsky, John Fuisz and Thomas Sykes published in October 16 issue of Legal Times. The Times article also said when asked what John thought Congress would do he said action was possible, recalling that six years ago doctors got Congress to protect them from patent infringement suits over surgical techniques. This article also appeared in the International Herald Tribune on October 19 and the Kansas City Star on October 25.
Paul Devinsky, John R. Fuisz, Thomas D. Sykes, Intellectual Property, Media & Technology, Tax
Art Rosen was quoted in the October 15 issues of State Income Tax Monitor and Sales & Use Tax Monitor in an article about a company official who tried to avoid liability for unpaid sales tax. In reference to the official's claim that the signatures on tax returns weren't his, Mr. Rosen said, "I'm surprised the state didn't try to get this guy for lying to them on top of what he owed. They must be getting soft or something."
Arthur R. Rosen, State & Local Tax, Tax
Joseph Rubinelli was quoted in the Fall 2006 issue of Wealth in an article about the challenges faced by estate planners as Congress continues to debate revisions to the federal estate tax. Mr. Rubinelli said, "Your plan needs to take into account your real beneficial priorities, so tax law changes don't leave a lopsided estate plan."
Joseph O. Rubinelli Jr., Private Client, Tax
Thomas Sykes was quoted in the October 1 issue of Financial Advisor magazine on the implications of granting patents for tax reduction methods. "For many strategies you consider that haven't been in the public domain for very long, you'll have to perform due diligence to make sure someone hasn’t patented them. It would be a major burden," Mr. Sykes said.
Thomas D. Sykes, Intellectual Property, Media & Technology, Tax
Peter Nias was quoted in the October 1 issue of International Tax Review on the negative impact of the British tax authority’s anti-arbitrage initiative on the certainty of advice he can give business clients.
Peter M.W. Nias, International Tax, London, Tax, Tax - London
Thomas Sykes was quoted in the October 2006 issue of The Chicago Lawyer in the article, "Patent attorneys, tax advisers square off over patenting tax strategies," about the controversy growing out of a surge in patents being granted for specific tax planning techniques. "Patents are allowing people to own a piece of the law. One arm of government is granting the tax benefit [while] another hand of government is taking away from it. It just runs counter to every instinct I think most of us have as to how law ought to work," Mr. Sykes said.
Thomas D. Sykes, Intellectual Property, Media & Technology, Tax
Peter Faber was mentioned in the September 5 issue of Tax Analysts about State Tax Notes publishing its 15th anniversary issue. Mr. Faber's essay on changes in tax practice over the last 15 years will appear in the issue.
Peter L. Faber, State & Local Tax, Tax
Carol Harrington was quoted in the September 4 issue of Fortune magazine about the U.S. Patent and Trademark Office granting patents to people who claim to have invented novel ways of avoiding taxes. "If you can patent an interpretation of the tax law, why not patent anyone's legal advice?" Ms. Harrington said.
Carol A. Harrington, Private Client, Tax
Tom Sykes was quoted in the September 1 issue of Tax Notes Today about the IRS' announcement that individual taxpayers can claim a telephone excise tax refund of between $30-$60, depending on family size without having to backup their refund claim with proof of the actual tax paid. Mr. Sykes said, "the standard amount under the August 31 IRS announcement might be overly generous to a residential subscriber who had a landline but not a cell phone throughout the 41-month period. But adding in taxes paid on cell phone service for just one line might bring the amount of tax paid over the past three years to over $70."
Thomas D. Sykes, Tax, Tax - Telecom
Art Rosen was quoted in the August 31 issue of Sales & Use Tax Monitor in an article detailing the pitfalls companies face in distributing promotional materials in different tax jurisdictions, where local laws may or may not levy sales or use taxes on the materials. Mr. Rosen noted that such a company would need to keep detailed records in case of an audit, and considering the difficulty involved they would have to make a decision. "Either you do want to do it on your own or make an arrangement with the company that's delivering the materials for you to keep track of where you are sending the items for tax purposes," Mr. Rosen said.
Arthur R. Rosen, State & Local Tax, Tax
Robin Greenhouse was quoted in the August 28 issue of Tax Notes about the Sixth Court reversing a district court order that compelled a company to provide documents to the IRS, remanding the case to the district court to grant the company's motion to quash the IRS summons because the documents sought are protected by work product privilege. "The Roxworthy opinion is important because it means another circuit has joined the majority view that work product protects documents prepared 'because of' anticipation of litigation," Ms. Greenhouse said.
Thomas Sykes was quoted in the July 24 edition of The Ledger about the demise of the phone tax. "Usually the government gives up after two or three circuit court losses. Here the IRS has been standing firm and hoping to win one of the active cases it has pending in other circuits so it can go before the Supreme Court," he said.
Domingo Such was quoted in the July 20 issue of The Wall Street Journal about the tax implications for money sent overseas. "There should be no U.S. gift or income tax consequences if money is sent directly from a foreign person to a U.S. bank account," said Mr. Such.
Domingo P. Such III, Private Client, Tax
Tom Sykes was quoted in the July 6 issue of the Tax Notes Today and the July 10 issue of Tax Notes in an article about how the IRS procedures for claiming refunds of telephone excise tax paid on long-distance service could undercut the ability of many taxpayers to receive timely refunds, or any at all, of amounts the Treasury Department has admitted it should never have collected. "The requirement that refund claims be made on taxpayers' 2006 return could easily delay final resolution of refund claims for corporations for four or five years," Mr. Sykes said. "The IRS has at least three years after the 2006 return is filed (in 2007) in which to examine the items on the return and companies and the IRS routinely agree to extensions of that three-year [statute of limitation], pushing finality out even further, he added.
Thomas D. Sykes, Tax, Tax - Telecom
Tom Jones was mentioned in the July 2006 edition of ABI/INFORM and Rough Notes about his suggestion leading to one of the International Center for Captive Insurance Education's newest initiatives. Mr. Jones' suggestion involved establishing an advisory counsel made up of various captive regulators.
Thomas M. Jones PC, Captive Insurance and Reinsurance, Insurance, Tax
Art Rosen was quoted in the June 30 issue of State Income Tax Monitor about rolling stock having a decent chance once they get beyond administrative appeals and into court. "I'd say it's about 50-50" odds, he said
Arthur R. Rosen, State & Local Tax, Tax
Susan Nash was quoted in the June 28 issue of Forbes.com in an article about the U.S. Internal Revenue Service proposing comprehensive, long-delayed rules for claiming dependent care tax breaks that will mean more savings for some working parents and less for others. "Employers are going to want to communicate the changes to employees, and employees need to pay attention so they put the right amount of money aside," warned Ms. Nash.
Susan M. Nash, Employee Benefits & Pensions, Tax
Philip McCarty was quoted in the June 15 issue of Technology News about how experts say the combination of a recent law with a new interpretation of U.S. tax code pertaining to inter-company payments may have a significant impact on technology companies by cutting off their ability to use the research and development tax credit. Mr. McCarty said the issue could have a big impact on tech companies. "The effect of it will be for a lot of companies that pay back dividends in 2005 to reduce or eliminate the credit for the next four years," he said. "The IRS is wrong on the issue and ignoring the statute."
Andrea Kramer was quoted in the June 2006 issue of Global Finance about how the corporate use of derivatives is becoming increasingly commonplace, but while they are easier than ever to use, the risks still remain. Credit derivatives are currently favored because they provide a hedge in case one of your close business partners falls on bad times. "If your biggest client is IBM, and you're afraid IBM is going to slip on a banana peel, you might get coverage based on IBM's creditworthiness," Ms. Kramer said.
Andrea S. Kramer, Financial Products, Trading & Derivatives, Structured Finance and Derivatives, Tax
Fred Chilton, Peter Faber, Jerry Kaplan, Peter Nias, Arndt Raupach, James Riedy, Art Rosen and Lowell Yoder were recommended in the Cross-border Tax on Corporate Transactions: PLC Which Lawyer Handbook published by Practical Law Company. McDermott was highly recommended.
Frederick Chilton, Peter L. Faber, Jared Kaplan, Peter M.W. Nias, Arndt Raupach, James A. Riedy PC, Arthur R. Rosen, Lowell D. Yoder, Germany, International, International Tax, London, Tax, Tax - Germany, Tax - London
Peter Faber was quoted in the May 31 issue of Technology News in regarding New York's new stance on the rule affecting telecommuters. When an employee lives in another state and is assigned to the employer's New York office, the days the person works at home won't be counted as New York days if the home office is a "bona fide employer office." Thus, these employees owe New York taxes only on their income from work actually done in the New York office. "The changes open the door for more genuine telecommuters to qualify," Mr. Faber said.
Art Rosen was quoted in the May 31 issue of State Income Tax Monitor and the June 15 issue of Sales & Use Tax Monitor in an article about RICO claims. "the bottom line is that it appears that RICO, proposed as a tool to force a company to collect tax by another taxpayer, is not allowable," he said.
Arthur R. Rosen, State & Local Tax, Tax
Peter Faber was quoted in the May 31 issue of The Wall Street Journal regarding New York's new stance on the rule affecting telecommuters. When an employee lives in another state and is assigned to the employer's New York office, the days the person works at home won't be counted as New York days if the home office is a "bona fide employer office." Thus, these employees owe New York taxes only on their income from work actually done in the New York office. "The changes open the door for more genuine telecommuters to qualify," Mr. Faber said.
Tom Sykes was quoted in the May 29 issue of the Tax Notes in an article about how the Treasury Department will finally abolish the telephone excise tax and will issue refunds to taxpayers for taxes paid on the disputed charges for the last three years. The new policy extends to wireless telephone services. "It surprises me, pleasantly, that the IRS gave up preemptively on wireless, in view of both the revenue involved and the fact that none of the decided cases addresses wireless," Mr. Sykes said.
Thomas D. Sykes, Tax, Tax - Telecom
Thomas Sykes was quoted in the May 26 issue of The Baltimore Sun in an article about how the government will finally abolish the telephone excise tax. "They had no choice but to end this tax," Mr. Sykes said. "It's not like Congress hasn't looked at this tax since 1898. The tax was actually overhauled by Congress in 1965. They were going to phase it out in 1969, but Congress couldn't resist the lure of the money. It became permanent in the 1990s," he added.
Thomas Sykes was quoted in the May 26 issue of the Tax Notes Today in an article about how the Treasury Department will finally abolish the telephone excise tax and will issue refunds to taxpayers for taxes paid on the disputed charges for the last three years. The new policy extends to wireless telephone services. "It surprises me, pleasantly, that the IRS gave up preemptively on wireless, in view of both the revenue involved and the fact that none of the decided cases addresses wireless," Mr. Sykes said.
Art Rosen was quoted in the May 15 issue of Sales & Use Tax Monitor in an article about the Streamlined Sales Tax Project. "It seems to me that the problems with enacting the laws in states like Tennessee, Ohio, Texas and Utah regarding origin-based sourcing will [effectively] keep them out of the process for the foreseeable future," he said.
Arthur R. Rosen, State & Local Tax, Tax
Jean Pawlow was quoted in the May 11 issue of Tax Notes Today in an article about how the Third Circuit ruled that the telephone excise tax does not apply to long distance services for which the charges do not vary by distance and time, becoming the fifth federal appeals court to invalidate the excise tax on those services. "Many taxpayers are anticipating that the Treasury will take action to resolve the many outstanding claims," Ms. Pawlow said.
Jean A. Pawlow, Tax, Tax - Telecom
Tom Sykes was quoted in the May 1 issue of Tax Notes Today in an article about how the Justice Department's Tax Division is refusing to give up the fight over the telephone excise tax despite its 11th straight loss and its 4th loss at the appeals level. The Second Circuit Court of Appeals ruled in April 27 in Fortis v. United States that the tax does not apply to certain flat-rate per-minute long-distance services. "The Department of Justice's opposition to the taxpayer's summary judgment motion appears to be designed just to buy time," said Mr. Sykes.
David Noren was mentioned in the May 1 issue of the Legal Times and the April 1 issue of International Tax Review regarding his move from the Joint Committee on Taxation to McDermott.
David G. Noren, International Tax, Tax
Tom Sykes was quoted April 20 in an article on CNNMoney.com about how the IRS has had a rough time defending a three percent tax on long-distance calls that dates from the Spanish-American War-its record is a painful one lower-court win and 10 losses, three of them in circuit courts and seven in lower courts. "Usually the government gives up after two or three circuit court losses," said Mr. Sykes. "Here the IRS has been standing firm and hoping to win one of the active cases it has pending in other circuits so it can go before the Supreme Court," he added.
David Noren was mentioned in the April 3 issue of the Washington Post regarding his move from the Joint Committee on Taxation to McDermott.
David Noren is listed in the March 31 issue ofThe Daily Deal regarding his move from the Joint Committee on Taxation to McDermott.
Steven Hannes was mentioned in the March 27 issues of Legal Times about being elected president of the USA Branch of the International Fiscal Association (IFA) and chair of its executive committee.
Steven P. Hannes, International Tax, Tax
David Fuller was quoted in the March 2006 issue of <