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2012

Date	Title
2011, n.2	Ripartizione del cinque per mille - Rassegna Tributaria Type: Articles Author(s): Alessio Persiani Practice Areas & Industries: Italy , Tax , Tax - Italy
2011, n.4	Riscossione coattiva e Convenzione europea dei diritti dell'uomo: alcune reflessioni - Rassegna Tributaria Type: Articles Author(s): Alessio Persiani Practice Areas & Industries: Italy , Tax , Tax - Italy
http://services.taxanalysts.com/taxbase/magdailypdfs.nsf/PDFs/63ST0215.pdf/$file/63ST0215.pdf	The New York Residency Wars Continue: Year-End Rulings - Tax Analysts Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: State & Local Tax , Tax
January 12, 2012	Not Just a Tax Issue: Lawsuits Crop Up Over IRS 162(m) - CFO.com Type: Articles Author(s): Andrew C. Liazos Practice Areas & Industries: Tax
January 2012	Current Federal Tax Developments: Cross-Border Equity Swap Withholding: Impact of Proposed NPC Regulations and Other Developments - Journal of Taxation of Financial Products Type: Articles Author(s): William R. Pomierski Practice Areas & Industries: Tax

2011

Date	Title
December 19, 2011	ISS Toughens Up View of Executive Comp - CFO Type: Articles Author(s): Andrew C. Liazos Practice Areas & Industries: Employee Benefits , Executive Compensation , Tax
December 18, 2011	The Tax Department's Role in Sustainable Transfer Pricing - International Tax Review Type: Articles Author(s): Hervé Bidaud Practice Areas & Industries: Paris , Tax
November 21, 2011	How to Avoid Tax Penalties on Deferred Comp - CFO Type: Articles Author(s): Andrew C. Liazos Practice Areas & Industries: Employee Benefits , Tax
November 11, 2011	Designing a Territorial Tax System for the United States - Tax Management International Journal - BNA Type: Articles Author(s): David G. Noren Practice Areas & Industries: Tax
2011	Taxation and Accounting XVI - Recent Developments in Public Utility, Communications and Transportation Industries 2011 Type: Books Author(s): Martha Groves Pugh Practice Areas & Industries: Energy Advisory , Tax
Fall 2011	Debt Ceiling Debate Portends Corporate Tax Reform - Infrastructure, Volume 51, Number 1, American Bar Association - ABA Section of Public Utility, Communications and Transport Law Type: Articles Author(s): Martha Groves Pugh Practice Areas & Industries: Corporate , Energy Advisory , Energy Tax , Tax
October 31, 2011	IRS Memorandum Offers Taxpayer Benefits Relating to Conversions of Insolvent Foreign Corporations Into Partnerships - Practical International Tax Strategies Type: Articles Author(s): Michael J. Wilder Practice Areas & Industries: International Tax , Tax
October 2011	Blog Contributor on Forbes.com - Forbes.com Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
October 17, 2011	U.S. Federal Income Tax Issues Arising From a Partial Disintegration of the Eurozone - Tax Analysts Type: Articles Author(s): Robert H. Dilworth Practice Areas & Industries: International Tax , Tax
Fall 2011	Two for One: How the NCAA Rules Do Not Adequately Address Package Deals and a Proposed Rule to Prohibit Them - Texas Review of Entertainment & Sports Law Type: Articles Author(s): Lauren A. Ferrante Practice Areas & Industries: State & Local Tax , Tax
October 11, 2011	Tax Savings Through Foreign Procurement - Forbes.com Type: Other Author(s): Lowell D. Yoder Practice Areas & Industries: International , International Tax , Tax
October 10, 2011	Financing Foreign Subsidiaries of U.S. Multinationals - Tax Management International Journal Type: Articles Author(s): Robert H. Dilworth , Caroline Hong Ngo Practice Areas & Industries: International Tax , Tax
October 2011	Making Patents Pay - Accountancy Magazine Type: Articles Author(s): James Ross Practice Areas & Industries: IP Litigation , IP, Media & Tech - London , London , Patent Prosecution , Tax , Tax - London
October 2011	Swap Assignments Safe Harbor Extended in Anticipation of Dodd-Frank Implementation - Journal of Taxation of Financial Products Type: Articles Author(s): William R. Pomierski Practice Areas & Industries: International Tax , Tax
September 2011	Current Federal Tax Developments: Swap Assignments Safe Harbor Extended in Anticipation of Dodd-Frank Implementation - Journal of Taxation of Financial Products Type: Articles Author(s): William R. Pomierski Practice Areas & Industries: Tax
August 2011	Clarification on Requirements for Dividend-Withholding Tax Reimbursements in Italy - Practical European Tax Strategies Type: Articles Author(s): Mario Martinelli Practice Areas & Industries: Tax , Tax - Italy
August 2011	Taxing the profits from patents in the UK - boxing clever - CIPA Type: Articles Author(s): James Ross Practice Areas & Industries: Intellectual Property , Tax
August 29, 2011	Tax Accrual Workpapers Redux - Tax Notes Type: Articles Author(s): Robin L. Greenhouse , Kevin Spencer Practice Areas & Industries: Tax , Tax Controversy
21, August 2011	Solidarità doppia per i manager: Dirigenti e collaboratori del settore finanziario scontano anche l'addizionale Irpef sui bonus - Il Sole 24 Ore Type: Articles Author(s): Andrea Tempestini Practice Areas & Industries: Italy , Tax , Tax - Italy
August 15, 2011	Clarification on Requirements for Dividend-Withholding Tax Reimbursements in Italy - EuroWatch Type: Articles Author(s): Mario Martinelli Practice Areas & Industries: Italy , Tax , Tax - Italy
June 27, 2011	Quill - Stare at the Decisision - Tax Analysts Type: Articles Author(s): Matthew P. Hedstrom , Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
June 15, 2011	Someone Might Sue N.Y. to Collect More Taxes from Your Company - State Income Tax Monitor Type: Articles Author(s): Jane Wells May Practice Areas & Industries: State & Local Tax , Tax
May 30, 2011	Section 338 Elections in the Age of Covered Asset Acquisitions - Tax Notes Type: Articles Author(s): Robert A. Clary II , Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
April 20, 2011	Wells Fargo Takes Up Cudgel to Protect Tax Accrual Workpapers - The National Law Review Type: Articles Author(s): Robin L. Greenhouse , Kevin Spencer Practice Areas & Industries: Tax
April 19, 2011	Wells Fargo Takes Up Cudgel to Protect Tax Accrual Workpapers - BNA Tax & Accounting Type: Articles Author(s): Robin L. Greenhouse , Kevin Spencer Practice Areas & Industries: Tax
April 4, 2011	New York's Statutory Residence Rule Should Be Repealed - Tax Analysts Special Report Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: Tax
2011	Variable Share Forward Contract Update: The IRS Reverses Course on Further Deferral Potential Through Delivery of Borrowed Shares - Journal of Taxation of Financial Products - CCH Type: Articles Author(s): William R. Pomierski Practice Areas & Industries: Tax
March 25, 2011	IRS Provides Guidance on Termination of 403(b) Plan - BNA Tax & Accounting Type: Articles Author(s): Todd A. Solomon Practice Areas & Industries: Employee Benefits , Tax
March/April 2011	Real Estate & Passthrough Finance Techniques Corner: "IRS Stretches to Help a Taxpayer in New Disguised Sale Private Letter Ruling" - Journal of Passthrough Entities Type: Articles Author(s): Jon Finkelstein , Blake D. Rubin , Andrea Macintosh Whiteway Practice Areas & Industries: Tax
March 18, 2011	The Danger Of Fiduciary Status For Valuation Firms - Law360 Type: Articles Author(s): Jonathan J. Boyles , Jeffrey Rothschild Practice Areas & Industries: Corporate , Employee Benefits , Employee Benefits Litigation , ESOPs , Tax
March 14, 2011	State Tax Day - Current, S.2 Special Feature: McDermott’s Arthur Rosen Interviews Recently Confirmed New York Commissioner Thomas Mattox - Wolters Kluwer News Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: Tax
February 25, 2011	Taxpayer Hunting Season in the Empire State: New York Expands Its False Claims Act to Include Tax Enforcement - Multistate Tax Report Type: Articles Author(s): Catherine A. Battin , Matthew Boch , Jane Wells May Practice Areas & Industries: State & Local Tax , Tax
February 2011	Intellectual Property Planning and the Creation of Value - Intellectual Property Magazine Type: Articles Author(s): Rohan Massey , Peter M.W. Nias Practice Areas & Industries: Intellectual Property , London , Tax
January 31, 2011	Illinois Bill Would Expand Attributional Nexus Concept to Untested Lengths - Tax Analysts Type: Articles Author(s): Catherine A. Battin , Matthew Boch , Thomas H. Donohoe , Lauren A. Ferrante Practice Areas & Industries: State & Local Tax , Tax
January 2010	Twombly is the Logical Extension of the Mathews v. Eldridge Test to Discovery - Florida Law Review Type: Articles Author(s): Andrew Blair-Stanek Practice Areas & Industries: Tax
2011	Navigating the Accounting Method Change Landscape - The New §381 Regulations and Other Developments - Tax Management Memorandum Type: Articles Author(s): Dwight N. Mersereau Practice Areas & Industries: Accounting Methods , Tax

2010

Date	Title
2010	Chapter 23: The New Generation of Nuclear Power - Energy and Environmental Project Finance Law and Taxation: New Investment Techniques Type: Books Author(s): Martha Groves Pugh Practice Areas & Industries: Energy Advisory , Energy Tax , Tax
December 1, 2010	So Last Century! - Spear's Magazine Type: Articles Author(s): Martyn Gowar Practice Areas & Industries: International Tax , London , Tax , Tax - London
December 2010	U.S. Taxation of Captives: Part 2 – Tax-Exempt Owners - Captive Insurance Company Reports Type: Articles Author(s): Michael N. Fine Practice Areas & Industries: Tax
November 30, 2010	U.S.--IRS Denies Tax Deferral and Long- Term Capital Gains through Basket Option Transaction - Practical International Tax Strategies - WorldTrade Executive Type: Articles Author(s): William R. Pomierski Practice Areas & Industries: Tax
November 26, 2010	States’ Extra-Statutory Attempts to Impose Sales Tax on Online Services Raise Questions of Fairness, Flouting of Legal Authority - Tax Management Multistate Tax Report - BNA Type: Articles Author(s): Leah Robinson , Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
November 2010	U.S. Taxation of Captives: Part 1 – Taxable Owners - Captive Insurance Company Reports Type: Articles Author(s): Michael N. Fine Practice Areas & Industries: Tax
Winter 2010	One Member Cooperative Subsidiary of a Rural Electric Cooperative Qualified as a Cooperative - The Cooperative Accountant Type: Articles Author(s): George W. Benson Practice Areas & Industries: Cooperatives , Tax
Winter 2010	Small Business Jobs Act of 2010: Cost Recovery Provisions of Interest to Cooperatives - The Cooperative Accountant Type: Articles Author(s): George W. Benson Practice Areas & Industries: Cooperatives , Tax
2010	Response to Jacobus on G-I Holdings - Tax Analysts Type: Articles Author(s): Jon Finkelstein , Blake D. Rubin , Andrea Macintosh Whiteway Practice Areas & Industries: Tax
August/September 2010	Foreign Employment Income in the Italian Tax Setting - IBFD Bulletin for International Taxation Type: Articles Author(s): Alessio Persiani Practice Areas & Industries: International Tax , Tax , Tax - Italy
October 2010	IRS Releases Final Schedule UTP and Instructions - BNA Tax & Accounting Type: Articles Author(s): Robin L. Greenhouse , Justin Jesse , Kevin Spencer Practice Areas & Industries: Tax
March 2010	UK Corporate Tax Update - Journal of International Taxation Type: Articles Author(s): James Ross Practice Areas & Industries: International Tax , Tax
September 2010	The Shifting Landscape of the Work Product Doctrine - Tax Report Type: Articles Author(s): Leah Robinson Practice Areas & Industries: State & Local Tax , Tax
September 13, 2010	Oregon Court Adds New Test for Nonbusiness Income in Liquidating Sale - Tax Analysts Special Report Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: State & Local Tax , Tax
September 10, 2010	Alternative Energy Podcast - Bloomberg Law Type: Other Author(s): Andrea S. Kramer Practice Areas & Industries: Energy Advisory , Tax
Fall 2010	Cooperative Tax Developments - Fall Newsletter, Mississippi Valley Chapter, National Society of Accountants for Cooperatives Type: Articles Author(s): George W. Benson Practice Areas & Industries: Cooperatives , Tax
monthly rubric	Tax Highlights - Neue Zeitrschrift für Gesellschaftsrecht (NZG) Type: Articles Author(s): Gero Burwitz Practice Areas & Industries: Tax , Tax - Germany
September/October 2010	The Tax Consequences of Settlement Agreements - Compensation & Benefits Review Type: Articles Author(s): Elizabeth Erickson , Ira B. Mirsky Practice Areas & Industries: Tax , Tax Controversy
September-October 2010	Transfer Pricing and Dispute Resolution—The U.K. Experience - International Tax Journal Type: Articles Author(s): Peter M.W. Nias Practice Areas & Industries: International Tax , London , Tax , Tax - London , Transfer Pricing
August 20, 2010	The current provision in the German annual taxation act - Der Betrieb Type: Articles Author(s): Dirk Pohl Practice Areas & Industries: Tax , Tax - Germany
2010	Energy and Environmental Project Finance Law and Taxation: New Investment Techniques - Oxford Type: Books Author(s): Andrea S. Kramer Practice Areas & Industries: Energy Advisory , Environmental , Tax
August 9, 2010	The States are Not Sovereign - State Tax Notes Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: State & Local Tax , Tax
August 9, 2010	When Is a Partner a Partner For New York Tax Purposes? - Tax Analysts Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: State & Local Tax , Tax
August 2010	Deloitte Decision Protects Work Product Disclosed to Independent Auditor - BNA Tax & Accounting Type: Articles Author(s): Robin L. Greenhouse Practice Areas & Industries: Tax
August 2010	Video, Increased State Business Taxes: Adjusting the Sales Factor - Financial Management Network Type: Other Author(s): Lindsay M. LaCava , Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
July 2010	New Protocol to Barbados-China Double Tax Agreement Enters into Force - Practical International Tax Strategies Type: Articles Author(s): Thomas W. Giegerich Practice Areas & Industries: International Tax , Tax
July 23, 2010	'Beginning Of Construction' Guidance For 1603 Grants - Law360 Type: Articles Author(s): Caroline Hong Ngo , Martha Groves Pugh , Philip Tingle Practice Areas & Industries: International Tax , Tax
July 20, 2010	Negotiating Over-the-Counter Derivative Contracts - Westlaw Business Currents Type: Articles Author(s): Andrea S. Kramer - Alton B. Harris Practice Areas & Industries: Financial Products, Trading & Derivatives , International Tax , Structured Finance and Derivatives , Tax
Fall 2010	Does Section 263A Apply to Grain Inventories Valued at Market? - The Cooperative Accountant Type: Articles Author(s): George W. Benson Practice Areas & Industries: Cooperatives , Tax
Fall 2010	Illinois Law Change Affecting Use of Losses - The Cooperative Accountant Type: Articles Author(s): George W. Benson Practice Areas & Industries: Cooperatives , Tax
July/August 2010	D.C. Circuit Jabs First Circuit – Work Product Means Something In the Nation’s Capital - TEI Magazine Type: Articles Author(s): Jean A. Pawlow , Kevin Spencer Practice Areas & Industries: Tax
July/August 2010	Potential Consequences of Work-Product Privilege in Tax Disputes: When Is Litigation Anticipated? - TEI Magazine Type: Articles Author(s): Thomas C. Borders PC , Brad McCormack Practice Areas & Industries: Tax
July 2010	CFCs--General Overview, 926-3rd T.M. - BNA Tax Management Foreign Income Portfolios Type: Books Author(s): Damon M. Lyon , David G. Noren , Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
2010	XIV. Taxation and Accounting - Recent Developments in Public Utility, Communications and Transportation Industries (2010 edition) Type: Articles Author(s): Martha Groves Pugh Practice Areas & Industries: Tax
June 14, 2010	Business Purpose, Economic Substance Don’t Apply to Intended Tax Benefits - Tax Analysts Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
June 3, 2010	Transfer Pricing Discussion Group's Comments on IRS Schedule UTP - Tax Management Transfer Pricing Report - BNA Type: Articles Author(s): Steven P. Hannes Practice Areas & Industries: International Tax , Tax , Transfer Pricing
Summer 2010	Correcting Code Section 409A Document Failures - ABA Section of Taxation News Quarterly Type: Articles Author(s): Brian A. Benko Practice Areas & Industries: Employee Benefits , Tax
Spring 2010	The Regulatory Systems for Employee Benefits - The Tax Lawyer Type: Articles Author(s): Brian A. Benko Practice Areas & Industries: Employee Benefits , Tax
April 5, 2010	NY's Shocking Stance on Taxing Online Services - E-Commerce Times Type: Articles Author(s): Leah Robinson , Arthur R. Rosen Practice Areas & Industries: Emerging Companies/Venture Financing , State & Local Tax , Tax
April 1, 2010	Credit Unions Prevail in Bellco Case, Section 199 Developments, & Ethanol Developments - The Cooperative Accountant Type: Articles Author(s): George W. Benson Practice Areas & Industries: Tax
April 2010	Teaching Hospitals, Ex-Residents, In Line For Billions In Tax Refunds - Forbes Type: Articles Author(s): Thomas C. Borders PC , David S. Ivill , Ira B. Mirsky Practice Areas & Industries: Health , Tax
March 31, 2010	ECJ Ruling on Italian Dividend Withholding Tax: Analysis and Ramifications - EuroWatch Type: Articles Author(s): Mario Martinelli , Alessio Persiani Practice Areas & Industries: Italy , Tax , Tax - Italy
March 22, 2010	The Privilege Two-Step - Tax Notes Type: Articles Author(s): Robin L. Greenhouse , Barbara W. Halevi Practice Areas & Industries: Tax , Tax Controversy
March 15, 2010	Where We've Been and Where We're Going—Taking Stock - State Tax Notes Type: Articles Author(s): Matthew P. Hedstrom Practice Areas & Industries: State & Local Tax , Tax
March 1, 2010	State RAR Reporting—Simplifying Unnecessary Complexities - State Tax Notes Type: Articles Author(s): Matthew P. Hedstrom Practice Areas & Industries: State & Local Tax , Tax
March 2010	Tax Havens and Tax Policy: How Should the U.S. Tax System Treat Income Earned by Multinationals in Low-Tax Jurisdictions? - TAXES—The Tax Magazine Type: Articles Author(s): David G. Noren Practice Areas & Industries: Tax
Spring 2010	Worthless Stock Losses from Liquidations and Related Issues in Consolidation - The Tax Executive Type: Articles Author(s): Andrew Blair-Stanek , Matthew K. White , Michael J. Wilder Practice Areas & Industries: International Tax , Tax
February 17, 2010	Section 199 & Grain Marketing Cooperatives Winter Newsletter - Mississippi Valley Chapter National Society of Accountants for Cooperatives - George Benson Type: Articles Author(s): George W. Benson Practice Areas & Industries: Tax
February 12, 2010	Notice 2008-91 Exception to §956: Guidance on Particular Issues - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
2003 to 2010	Corporation Business Tax Chapter; Sales & Use Tax Chapter - New Jersey Tax Guide - American Lawyer Media Type: Books Author(s): Practice Areas & Industries: State & Local Tax , Tax
February 1, 2010	Business Purpose and Economic Substance in State Taxation - Tax Analysts Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: State & Local Tax , Tax
January/February 2010	Commissionaire Agreements: Some Remarks in View of the Recent Italian Tax Authorities Challenges - International Tax Journal Type: Articles Author(s): Carlo Maria Paolella , Alessio Persiani Practice Areas & Industries: Italy , Tax , Tax - Italy
January 4, 2010	Putting the ‘Fair’ Back in Fair Apportionment - State Tax Notes Type: Articles Author(s): Matthew P. Hedstrom Practice Areas & Industries: State & Local Tax , Tax
2010	G-I Holdings: A Court Finally Speaks on Partnership Disguised Sales of Property, but Should Anyone Listen? - Journal of Passthrough Entities Type: Articles Author(s): Jon Finkelstein , Blake D. Rubin , Andrea Macintosh Whiteway Practice Areas & Industries: Tax
January 2010	Narrowing the Scope of Work-Product Protection: First Circuit Decision Puts Taxpayers on Notice - Taxes – The Tax Magazine - CCH Type: Articles Author(s): Robin L. Greenhouse Practice Areas & Industries: Tax
2010	Partnership Disguised Sales: G-I Holdings Misses the Mark - Tax Notes Type: Articles Author(s): Jon Finkelstein , Blake D. Rubin , Andrea Macintosh Whiteway Practice Areas & Industries: Tax
January–March 2010	SALT Shaker Newsletter - Co-author Type: Articles Author(s): Matthew P. Hedstrom Practice Areas & Industries: State & Local Tax , Tax

2009

Date	Title
December 21, 2009	Unclaimed Property Administration—Taking Advantage of Uncertainty - State Tax Notes Type: Articles Author(s): Matthew P. Hedstrom Practice Areas & Industries: State & Local Tax , Tax
Winter 2009	Quarterly Column - The Cooperative Accountant Type: Articles Author(s): George W. Benson Practice Areas & Industries: Tax
November 16, 2009	FTB Proposes Amendments to Sales Factor Cost of Performance Regs - Tax Analysts Type: Articles Author(s): Roy E. Crawford Practice Areas & Industries: State & Local Tax , Tax
November/December 2009	Tax Consequences of Employment Cases - Journal of Compensation and Benefits Type: Articles Author(s): Elizabeth Erickson , Ira B. Mirsky Practice Areas & Industries: Employee Benefits , Tax
October 9, 2009	Subpart F: "Indicia of Manufacturing" - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
September 21, 2009	Proposed Multilateral FTC Pooling and U.S. Bilateral Tax Treaties - Tax Notes; Worldwide Tax Daily - Tax Analysts Type: Articles Author(s): Robert H. Dilworth Practice Areas & Industries: Tax
September 21, 2009	States Attempt to Seize Class Action Settlements as Unclaimed Property - State Tax Notes Type: Articles Author(s): Matthew P. Hedstrom Practice Areas & Industries: State & Local Tax , Tax
September 11, 2009	Legal Alert: IRS Provides Guidance on the Taxation of Employment-Related Settlement Payments - Employee Benefit News Type: Articles Author(s): Elizabeth Erickson , Ira B. Mirsky Practice Areas & Industries: Employee Benefits , Tax
September/October 2009	As Finalized, Section 362(e)(2) Does Not Apply to Intercompany Transactions, Unless It Does - Corporate Taxation Type: Articles Author(s): Robert A. Clary II Practice Areas & Industries: Tax
September 2009	M&A in the Commodities Sector: Still Going Strong - Practical Law Company Magazine Type: Articles Author(s): Rashpaul Bahia , Hugh Nineham , Prajakt Samant Practice Areas & Industries: Antitrust & Competition , Corporate , Energy Advisory , Finance & Banking , Mergers & Acquisitions , Tax
September / October 2009	The Reclassification of DEs as CFCs Under Obama's CTB Proposal Can Result in Subpart F Income - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Fall 2009	Third Time's NOT a Charm: En Banc First Circuit Permits IRS to Obtain Roadmap to "Soft Spots" on Textron's Returns - The Tax Executive Type: Articles Author(s): Jean A. Pawlow , Kevin Spencer Practice Areas & Industries: Tax , Tax Cases
August 14, 2009	Obama Administration's Proposal to Limit Classification of Foreign Entities as Disregarded is Misguided - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Summer 2009	Bernie Madoff "Made Off" with My Investment: Evaluating the Tax Options Available for Victims of Fraudulent Investments - Journal of Taxation of Financial Products Type: Articles Author(s): Andrea S. Kramer , Thomas P. Ward Practice Areas & Industries: Financial Products, Trading & Derivatives , Tax
July 24, 2009	Benefit Plan Audits: New Tips From the IRS - SHRM Legal Report Type: Articles Author(s): James G. Isaac , Susan Peters Schaefer , Karen A. Simonsen Practice Areas & Industries: Employee Benefits , Tax
June 22, 2009	Sogg v. Zurz: Unclaimed Property—Do You Own Your Income? - State Tax Notes Type: Articles Author(s): Matthew P. Hedstrom Practice Areas & Industries: State & Local Tax , Tax
July 15, 2009	Compaq: Find Another Poster Child. The Business Purpose Doctrine is Alive and Well in the Fifth Circuit - International Tax Journal Type: Articles Author(s): Robert H. Dilworth Practice Areas & Industries: International Tax , Tax
July 2009	Chapter 9: Appeals - State Business Taxes Type: Books Author(s): Lindsay M. LaCava , Leah Robinson , Arthur R. Rosen - Lindsay M. LaCara Practice Areas & Industries: State & Local Tax , Tax
June - July 2009	Tax-Efficient Business Practices in the Face of Unprecedented International Tax Enforcement - Bank Accounting & Finance Type: Articles Author(s): Matthew Boch , Gregory G. Palmer - This article is reprinted with the publisher's permission from BANK ACCOUNTING & FINANCE, a bi-monthly journal published by CCH INCORPORATED. Copying or distribution without the publisher's permission is prohibited. To subscribe to BANK ACCOUNTING & FINANCE or other CCH Journals please call 800-449-8114 or visit www.tax.cchgroup.com. All views expressed in the articles and columns are those of the author and not necessarily those of CCH INCORPORATED or any other person. Practice Areas & Industries: International Tax , Tax , Tax Controversy
July / August 2009	Obama Administration's International Tax Proposals - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
June 12, 2009	Limits on the Application of the Subpart F Branch Rules - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
June/July 2009	Tax-Efficient Business Practices in the Face of Unprecedented International Tax Enforcement - Bank Accounting & Finance Type: Articles Author(s): Matthew Boch , Gregory G. Palmer Practice Areas & Industries: Tax , Trial
Spring 2009	Chapter: Never Thought I'd Be a Constitutional Lawyer - ABA Careers in Taxation Type: Books Author(s): Leah Robinson Practice Areas & Industries: Tax
May 2009	Commentary on Sec. 24 and 25 German Corporate Income Tax Code - Herrmann/Heuer/Raupach, Commentary on Income Tax and Corporate Income Tax Code - Otto-Schmidt-Verlag Type: Other Author(s): Gero Burwitz Practice Areas & Industries: Germany , Tax
May / June 2009	New Code Sec. 367(a) Regulations Apply to International Code Sec. 304(a)(1) Transactions - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
April 10, 2010	New Temporary Regulations Fundamentally Alter Operation of §304 and the Application of §1248 - Tax Management International Journal Type: Articles Author(s): Caroline Hong Ngo Practice Areas & Industries: International Tax , Tax
April 10, 2009	Same-Country-of-Manufacture Exception to Subpart F Sales Income - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
April 2009	Lessons to Nonprofits from the IRS Hospital Report - The Exempt Organization Tax Review Type: Articles Author(s): Ralph E. DeJong , Michael W. Peregrine Practice Areas & Industries: Health , Nonprofit Organizations , Tax , Tax Exemption
March 30, 2009	The Proposed New U.K. Worldwide Debt Cap - Tax Notes International Type: Articles Author(s): James Ross Practice Areas & Industries: International Tax , Tax , Tax - London
March 13, 2009	Improving Efficiency of Global Cash Utilization Accelerated Payments for Inventory - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
March / April 2009	Final and Temporary Subpart F Contract Manufacturing Regulations - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
February 18, 2009	"IRS' Hospital Industry Report" – AHLA Tax and Finance and Governance Practice Group" Type: Articles Author(s): Ralph E. DeJong , Michael W. Peregrine Practice Areas & Industries: Corporate Responsibility and Governance , Health , Tax , Tax Exemption
February 2009	Industry Comment Column - Captive Review Type: Articles Author(s): Thomas M. Jones PC Practice Areas & Industries: Captive Insurance and Reinsurance , Tax
February 2009	Stimulating US Renewables - Project Finance International Type: Articles Author(s): Philip Tingle Practice Areas & Industries: Corporate , Energy - London , Energy Advisory , Energy Tax , Global Renewable Energy, Emissions and New Products , Tax
January 2009	IRS Issues Initial Guidance and Limited Transition Relief for Nonqualified Deferred Compensation Plans Subject to New Section 457A - BNA Tax Management Commentary Type: Articles Author(s): Joseph S. Adams , Andrew C. Liazos , David G. Noren , Stephen Pavlick PC , William R. Pomierski , David E. Rogers , Thomas P. Ward Practice Areas & Industries: Employee Benefits , Executive Compensation , Tax
monthly rubric	Tax Highlights - Neue Zeitschrift für Gesellschaftsrecht NZG Type: Articles Author(s): Gero Burwitz Practice Areas & Industries: Germany , Tax , Tax - Germany
January 9, 2009	Gleanings from §956 Developments - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
January/February 2009	The New York State Insurance Department and Credit Default Swaps: Good Intentions, Bad Idea - Journal of Taxation and Regulation of Financial Institutions Type: Articles Author(s): Andrea S. Kramer Practice Areas & Industries: Hedge Funds , Insurance , Tax
January 5, 2009	Vondjidis v. Hewlett Packard: Sacrificing Good Unclaimed Property Policy In Search of Perfect Compliance? - State Tax Notes Type: Articles Author(s): Matthew P. Hedstrom Practice Areas & Industries: State & Local Tax , Tax
January/February 2009	Adrift In a Sea of Uncertainty: Tax Accrual Workpapers Are Work-Product...But Showing Them to Your Auditor May Waive the Protection - The Tax Executive Type: Articles Author(s): Jean A. Pawlow , Kevin Spencer Practice Areas & Industries: Tax , Tax Cases
2009	Cancellation of Indebtedness Income Deferral in Economic Stimulus Bill Raises Complex Issues for Partnerships - Journal of Passthrough Entities Type: Articles Author(s): Jon Finkelstein , Blake D. Rubin , Andrea Macintosh Whiteway Practice Areas & Industries: Tax
2009	Employers' Responsibilities When Making Settlements in Employment-Related Claims - Bloomberg Law Reports - Employee Benefits Type: Articles Author(s): Elizabeth Erickson , Ira B. Mirsky Practice Areas & Industries: Employee Benefits , Tax
Q1 2009	Interview with an Icon: Tom Jones - 180º - Strategic Risk Solutions Type: Articles Author(s): Thomas M. Jones PC Practice Areas & Industries: Captive Insurance and Reinsurance , Insurance Companies and Products Tax , Nonprofit Organizations , Tax
2009	New COD Income Deferral Guidance Provides Flexibility for Partnerships - Tax Notes Type: Articles Author(s): Jon Finkelstein , Blake D. Rubin , Andrea Macintosh Whiteway Practice Areas & Industries: Tax
2009	New Cancellation of Indebtedness Income Deferral in Economic Stimulus Bill - Journal of Passthrough Entities Type: Articles Author(s): Jon Finkelstein , Blake D. Rubin , Andrea Macintosh Whiteway Practice Areas & Industries: Tax
January / February 2009	Notice 2008-91 Expands Code Sec. 956 Exception for Short Term Obligations - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
2009	Recent Developments in Partnership Taxation - 2009 USC Tax Institute Major Tax Planning Type: Articles Author(s): Gale E. Chan , Jon Finkelstein , Blake D. Rubin Practice Areas & Industries: Tax
2009	Rev. Proc. 2009-37 Provides Flexibility for Partnership Debtors Deferring COD Income - Journal of Passthrough Entities Type: Articles Author(s): Jon Finkelstein , Blake D. Rubin , Andrea Macintosh Whiteway Practice Areas & Industries: Tax
Volume I, Issue 6 2009	Safe Harbor or Not: Tax Issues for the Victims of Ponzi Schemes - Investigations Quarterly Type: Articles Author(s): Andrea S. Kramer , Thomas P. Ward Practice Areas & Industries: Tax
2009	Stimulus COD Income Deferral Raises Issues for Partnerships - Tax Notes Today Type: Articles Author(s): Jon Finkelstein , Blake D. Rubin , Andrea Macintosh Whiteway Practice Areas & Industries: Tax
2009	Tax Issues in Defeasing a Conduit Loan, Including in a Like-Kind Exchange - 67 N.Y.U. Federal Tax Institute Type: Articles Author(s): Jon Finkelstein , Andrea Macintosh Whiteway Practice Areas & Industries: Tax
2009	Tax Planning for Partnership Options and Compensatory Equity Interests - 67 N.Y.U. Federal Tax Institute Type: Articles Author(s): Jon Finkelstein , Blake D. Rubin Practice Areas & Industries: Tax
January/February 2009	Tax Reform: International Tax Issues and Some Proposals - International Tax Journal Type: Articles Author(s): Robert H. Dilworth Practice Areas & Industries: International Tax , Tax
2009	Working with the Partnership Liability Allocation Rules: Guarantees, DROs and More - 68 N.Y.U. Federal Tax Institute Type: Articles Author(s): Jon Finkelstein , Blake D. Rubin , Andrea Macintosh Whiteway Practice Areas & Industries: Tax
2009	XIV. Taxation and Accounting - Annual Report of the Public Utility, Communications and Transportation Section (2009 edition) Type: Articles Author(s): Martha Groves Pugh Practice Areas & Industries: Tax

2008

Date	Title
December 18, 2008	New 409A Guidance Issued, 457A Guidance Expected Shortly - BNA Tax Management Commentary Type: Articles Author(s): Joseph S. Adams , Andrew C. Liazos Practice Areas & Industries: Employee Benefits , Executive Compensation , Tax
Issue 22, 2008	Tax liability of the restructuring benefit - GmbH Rundschau Type: Articles Author(s): Peter Bauschatz Practice Areas & Industries: Tax , Tax - Germany
November / December 2008	The Subpart F Physical Manufacturing Exception - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
October 10, 2008	Foreign Subsidiary's Acquisition of a Foreign Target with U.S. Parent Stock - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
18/2008, S.694-99	German Accounting Law Modernization Act (BilMoG) - Neue Zeitschrift für Gesellschaftsrecht (NZG) Type: Articles Author(s): Gero Burwitz Practice Areas & Industries: Germany , Tax , Tax - Germany
September 2008	IRS hits stone wall in quest for tax accrual workpapers - International Tax Review Type: Articles Author(s): Robin L. Greenhouse , Kevin Spencer Practice Areas & Industries: Tax , Tax Controversy
September / October 2008	Proposed Regs Address Application of Subpart F Branch Rule Where All Acitivites Are Conducted in a Branch - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
08/2008	Business Law - Joint-Venture-Companies (2. Edition) - RWS-Verlag Type: Books Author(s): Dirk Pohl , Norbert Schulte Practice Areas & Industries: Corporate , Germany , Tax
August 2008	Private Trust Companies - Trusts & Estates Type: Articles Author(s): Ryan M. Harding , Carol A. Harrington Practice Areas & Industries: Tax
August 8, 2008	Subpart F: The Proposed Non-Physical Manufacturing Branch - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
August 2008	Chapter 13: Building a Compliance Infrastructure for Energy Trading Employees - Energy and Environmental Trading: US Law and Taxation Type: Books Author(s): Andrea S. Kramer Practice Areas & Industries: Energy Tax , Tax
August 2008	Chapter 17: Federal and State Tax Issues for Energy Trading Companies - Energy and Environmental Trading: US Law and Taxation Type: Books Author(s): Andrea S. Kramer Practice Areas & Industries: Energy Tax , Tax
August 2008	Chapter 18: Special Tax Rules for Certain Energy Futures Contracts and Options - Energy and Environmental Trading: U.S. Law and Taxation Type: Books Author(s): William R. Pomierski Practice Areas & Industries: Energy Tax , Tax
August 2008	Energy and Environmental Trading: U.S. Law and Taxation - Cameron May Ltd Type: Books Author(s): Andrea S. Kramer Practice Areas & Industries: Energy Tax , Tax
August 2008	IRS Updates Qualified Plan Correction Program - BNA Tax Management Commentary Type: Articles Author(s): Joseph S. Adams , Brett R. Johnson , Stephen R. Miller Practice Areas & Industries: Employee Benefits , Tax
2008	Business and Property Succession - Der Betrieb - Unternehmens- und Vermögensnachfolge - Schaeffer/Poechel-Verlag Type: Articles Author(s): Dirk Pohl Practice Areas & Industries: Tax
monthly rubric	Tax Highlights - Neue Zeitschrift für Gesellschaftsrecht NZG Type: Articles Author(s): Gero Burwitz Practice Areas & Industries: Germany , Tax , Tax - Germany
July 11, 2008	“Financing Foreign Subsidiaries of U.S. Multinationals” - 37 Tax Management International Journal No. 7 Type: Articles Author(s): Robert H. Dilworth Practice Areas & Industries: Tax
July / August 2008	Subpart F: The Same-Country-of-Manufacture Exception - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
June 26, 2008	The Foundation of International Tax Reform: Worldwide, Territorial and Something in Between - Statement to the Senate Finance Committee Type: Other Author(s): Robert H. Dilworth Practice Areas & Industries: International Tax , Tax
June 16, 2008	Disregarding’ a Liquidation: The Bizarre Browning-Ferris Case - Tax Notes Type: Articles Author(s): Robert A. Clary II , Kevin J. Feeley Practice Areas & Industries: Pass-Throughs , Tax
June 13, 2008	Subpart F Manufacturing Exception: Proposed Non-Physical Definition of Manufacturing - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
2008	“Financing International Operations of U.S. Multinationals” - PLI/Tax Tax Strategies for Corporate Acquisitions, Dispositions, Spin-offs, Joint Ventures, Financings, Reorganizations & Restructurings 2008 Type: Articles Author(s): Robert H. Dilworth Practice Areas & Industries: Tax
2008	Yearbook Tax Lawyers - Arbeitsgemeinschaft der Fachanwälte für Steuerrecht e.V. Type: Books Author(s): Dirk Pohl Practice Areas & Industries: Tax
May 26, 2008	Setting the Record Straight on the Business Activity Tax Simplification Act - State Tax Notes Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
May 2008 / June 2008	Foreign Tax Credits - International Tax Journal Type: Articles Author(s): James A. Riedy PC Practice Areas & Industries: International Tax , Tax
May / June 2008	Proposed Subpart F Contract Manufacturing Regulations - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
5/2008	Strengthening of Equity through IP? How the Accounting Law Reform Act shall open the door to credits for the innovative German Mittelstand - Absatzwirtschaft Type: Articles Author(s): Gero Burwitz Practice Areas & Industries: Germany , Tax , Tax - Germany
April 14, 2008	Stop the State Tax Grab - Legal Times Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
April 11, 2008	2007 Technical Corrections to Sec. 954(c)(6) - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
April 2008	Current Trends in Transfer Pricing and Business Reorganizations - Tax Notes International, Volume 50, Number 3 Type: Articles Author(s): Lee Khvat , Peter M.W. Nias , James Ross Practice Areas & Industries: London , Tax , Tax - London , Transfer Pricing
2008	Football - the game between idealism and commerce - SpuRt - Sport und Recht Type: Articles Author(s): Arndt Raupach Practice Areas & Industries: Sports & Entertainment , Tax
2008	German corporate tax reform - Tax Directors Handbook Type: Articles Author(s): Gero Burwitz Practice Areas & Industries: Tax
March 14, 2008	Notice 2008-10: The IRS and Treasury Continue Their Assault on Tax-Free Earnings Repatriations - Tax Management International Journal Type: Articles Author(s): Philip A. McCarty , Timothy S. Shuman Practice Areas & Industries: Tax , Tax Controversy
March / April 2008	CFC Purchase of Stock in a Related CFC: Code Sec. 304 vs. D Reorganization Treatment - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
January 2008	Commentary on Sec. 23 German Corporate Income Tax Code - Herrmann/Heuer/Raupach, Commentary on Income Tax and Corporate Income Tax Code - Otto-Schmidt-Verlag Type: Other Author(s): Gero Burwitz Practice Areas & Industries: Germany , Tax , Tax - Germany
February 8, 2008	Cash D Reorganizations—Selected International Issues - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
January 2008	Foreign Tax Credits - International Tax Journal Type: Articles Author(s): James A. Riedy PC Practice Areas & Industries: Tax
January / February 2008	Short-Term CFC Loans May Avoid Code Sec. 956 - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
January 2008	Intellectual Property Holding Companies: Tax Panacea or IP Mistake? - Global Intellectual Property Asset Management Report Type: Articles Author(s): Paul Dau , Paul Devinsky Practice Areas & Industries: Intellectual Property , Patent Prosecution , Tax

2007

Date	Title
2007	Business Operations in Germany - Tax Management - BNA Tax Management Type: Books Author(s): Dirk Pohl Practice Areas & Industries: International Tax , Tax , Tax - Germany
11/2007	Carrot and stick; tax rate reduction, interest rate barrier, the purchase of loss - Going Public Magazin Type: Articles Author(s): Gero Burwitz Practice Areas & Industries: Tax
December 2007	German corporate tax reform, 2008 - Tax Directors Handbook 2008 Type: Articles Author(s): Gero Burwitz Practice Areas & Industries: Germany , Tax , Tax - Germany
11/2007	The fiscal reform in Germany 2008 - Going Public Type: Articles Author(s): Gero Burwitz Practice Areas & Industries: Germany , Tax , Tax - Germany
November / December 2007	Gain Derived by a CFC from the Sale of a Business - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
2007	Separate vs. Integrated Contracts, Foreign Currency Contracts Under Code Sec. 1256, Prepaid Forwards and Contingent Exchange Traded Notes - Journal of Taxation of Financial Products Type: Articles Author(s): William R. Pomierski Practice Areas & Industries: Financial Products, Trading & Derivatives , Tax
October 28, 2007	IRS Applies Section 956 Thirty-Day Exception to Quarters - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
October 15, 2007	Textron Protects Tax Accrual Workpapers from IRS Summons - Tax Notes Type: Articles Author(s): Robin L. Greenhouse , Michael F. Kelleher Practice Areas & Industries: Tax , Tax Controversy
October 13, 2007	A Bird’s Eye View of §367’s Application to Triangular Reorganizations Involving CFCs - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
2007	Code Sec. 1256 Considerations for ICE Futures and Beyond - Journal of Taxation of Financial Products Type: Articles Author(s): William R. Pomierski Practice Areas & Industries: Financial Products, Trading & Derivatives , Tax
Fall 2007	Hands-Off My Tax Accrual Workpapers: Textron, FIN 48, and Related Issues - The Tax Executive Magazine Type: Articles Author(s): Jean A. Pawlow , Stephen M. Ryan , Kevin Spencer Practice Areas & Industries: Tax , Tax Controversy
October 2007	U.S. Private Equity Funds Making Cross-Border Investments - Primary Tax Considerations - Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2007 Type: Articles Author(s): Timothy S. Shuman Practice Areas & Industries: Tax , Tax - Private Equity
Fall 2007	Using Insurance Law and Policy To Interpret the Tax Code’s Loss and Medical Expense Provisions - Yale Law and Policy Review Type: Articles Author(s): Andrew Blair-Stanek Practice Areas & Industries: Tax
September 4, 2007	U.S. Private Equity Funds Making Cross-Border Investments - Primary Tax Considerations - VC Experts' Encyclopedia of Private Equity and Venture Capital Type: Articles Author(s): Timothy S. Shuman Practice Areas & Industries: Tax , Tax - Private Equity
September/October 2007	"U.S. Tax Treatment of Contract Manufacturing Arrangements: Change Afoot?" - IBFD International Transfer Pricing Journal Type: Articles Author(s): David G. Noren Practice Areas & Industries: Tax , Transfer Pricing
2007	Interest Rate Hedging Considerations for Corporate Taxpayers - Journal of Taxation of Financial Products Type: Articles Author(s): William R. Pomierski Practice Areas & Industries: Financial Products, Trading & Derivatives , Tax
September / October 2007	Notice 2007-48: IRS Takes a Shot at Public Triangular Reorganizations - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
September 2007	business tax from a view of of a tax lawyer - publication in honor of Winfried Mellwig Type: Articles Author(s): Arndt Raupach Practice Areas & Industries: Germany , Tax , Tax - Germany
Issue 47/2007	market value as the sole yardstick for evaluation purposes of inheritance and gift tax, the earning-capacity value is dead, long live the e.-c. value - DstR Type: Articles Author(s): Arndt Raupach Practice Areas & Industries: Tax
August 24, 2007	Irrationality, Inconsistency, and Discrimination: Why New Jersey’s Throw-Out Rule Is Unconstitutional - Multistate Tax Report Type: Articles Author(s): Leah Robinson Practice Areas & Industries: State & Local Tax , Tax
August 10, 2007	Application of Subpart F to Gain Derived by a CFC from the Sale of a Business: Form Matters - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
July 23, 2007	New Combined Reporting Rules for New York State - State Tax Notes Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: State & Local Tax , Tax
July / August 2007	International Planning Using Code Sec. 304(a)(1) - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
June 18, 2007	State AGs' Power Over Nonprofits After 'Spitzer v. Grasso' - The National Law Journal Type: Articles Author(s): Ralph E. DeJong , Michael W. Peregrine Practice Areas & Industries: Executive Compensation , Nonprofit Organizations , Tax , Tax Exemption
June 8, 2007	Practical Applications of the CFC Look-Thru Rule Under Notice 2007-9 - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
June 2007	U.S. Private Equity Funds making Cross-Border Investments-Primary Tax Considerations - Journal of Taxation Type: Articles Author(s): Timothy S. Shuman Practice Areas & Industries: Tax , Tax - Private Equity
May 11, 2007	Notice 2007-13: New Subpart F Substantial Assistance Rule - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
May 9, 2007	Reimbursement of Italian dividend tax violating European law - ZSteu Zeitschrift für Steuern und Recht Type: Articles Author(s): Carsten Steinhauer Practice Areas & Industries: Italy , Tax , Tax - Italy
May/June 2007	As Proposed, Section 362(e)(2) Does Not Apply to Intercompany Transactions, Unless It Does - Journal of Corporate Taxation Type: Articles Author(s): Robert A. Clary II Practice Areas & Industries: Tax , Tax - Acquisitions & Restructurings
May / June 2007	Code Sec. 338(g) Election Applied to Foreign Targets: Permissible Tax Arbitrage - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
May/June 2007	“Credit Risk Management in the European Day-Ahead Power Markets,” - Futures Industry Type: Articles Author(s): Andrea S. Kramer , Prajakt Samant Practice Areas & Industries: Energy Tax , Tax
monthly rubric	Tax Highlights - Neue Zeitschrift für Gesellschaftsrecht NZG Type: Articles Author(s): Gero Burwitz Practice Areas & Industries: Germany , International , Tax , Tax - Germany
Spring 2007	Energy Derivatives Through Federal and State Tax Glasses - Journal of Taxation of Financial Products Type: Articles Author(s): Andrea S. Kramer Practice Areas & Industries: Energy Advisory , Energy Tax , Tax
March, 31 2007	German Cabinet Approves Corporate Tax Plan 2008 - EuroWatch Type: Articles Author(s): Gero Burwitz , Dirk Pohl Practice Areas & Industries: Germany , International , Tax
March-April 2007	A Fresh Start for a Troubled QBU - International Tax Journal Type: Articles Author(s): Caroline Hong Ngo Practice Areas & Industries: International Tax , Tax
March 23, 2007	Apportionment in Gross Receipts Taxes: A Brief Analysis of Constitutional Questions About Methods and Standards - BNA Tax Management Multistate Tax Report Type: Articles Author(s): Practice Areas & Industries: State & Local Tax , Tax
March 2007	Energy Trading Law, Part II - The Risk Desk Type: Articles Author(s): Andrea S. Kramer Practice Areas & Industries: Energy Advisory , Energy Tax , Tax
January 2007, Volume 9, Number 1	Italy-Infringement Procedure against Italy and ECJ Ruling Prepare Grounds for Reimbursement of Dividend Tax - Practical European Tax Strategies Type: Articles Author(s): Mario Martinelli , Carsten Steinhauer Practice Areas & Industries: Corporate , Italy , M&A and Corporate - Italy , Tax , Tax - Italy
March 5, 2007	constructive dividends and hidden deposits according to German Annual Tax Act 2007 - formally and materially correspondence - FR - Finanz-Rundschau Type: Articles Author(s): Dirk Pohl , Arndt Raupach Practice Areas & Industries: International Tax , Tax
March / April 2007	Updating the Subpart F Rules for Active Income - International Tax Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
February, 2007	New Book: Energy Trading Law - The Risk Desk Type: Articles Author(s): Andrea S. Kramer Practice Areas & Industries: Energy Advisory , Energy Tax , Tax
February 9, 2007	Adjustments to Stock Basis in Lower-Tier CFCs - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
15 January 2007	Government Attempts to Limit Tax Exemptions for Non-German Companies - Euro Watch Type: Articles Author(s): Gero Burwitz - Phillip Neuman-Redlin Practice Areas & Industries: Germany , Tax , Tax - Germany
2007	Employers' Handbook: Complying With IRS Employee Benefits Rules Type: Books Author(s): Susan M. Nash Practice Areas & Industries: Employee Benefits , Tax
2007 Symposium Edition	The Final Word: Congress and the Express Commerce Clause - State and Local Tax Lawyer Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax

2006

Date	Title
12/8/06	Final §367(b) Attribute Regulations-Highlights and Planning Considerations - Tax Management International Journal Type: Articles Author(s): Philip A. McCarty Practice Areas & Industries: International Tax , Tax
December 8, 2006	PTI Sharing Under the Proposed §959 Regulations - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
2006	Editors: Susan Nash, David Fuller - Employers' Handbook: Complying With IRS Employee Benefits Rules Type: Articles Author(s): Susan M. Nash Practice Areas & Industries: Employee Benefits , Tax
Winter 2006	Intangible Property Used Outside the U.S.: Active vs. Passive Treatment of Royalties and Gain - JTGT Type: Articles Author(s): Damon M. Lyon , Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
December 2006	One cell captive or two traditional captives? - Cayman Islands Journal Type: Articles Author(s): Thomas M. Jones PC Practice Areas & Industries: Insurance , Tax
Winter 2006	President's Advisory Panel Recommendations Concerning Taxation of Foreign Income - JTGT Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
December 2006	Tax presentation highlights recent IRS rulings - Cayman Islands Journal Type: Articles Author(s): Thomas M. Jones PC Practice Areas & Industries: Insurance , Tax
November 2006	Commission Cites Spain's Capital Gains Tax - Practical European Tax Strategies Type: Articles Author(s): Andrea L. Hamilton Practice Areas & Industries: International Tax , Tax
November 2006	Payment of Medical Expenses for Non-Dependent Beneficiary Renders All HRA Reimbursements Taxable - Complying with IRS Employee Benefit Plan Rules Type: Articles Author(s): Joanna C. Kerpen , Todd A. Solomon Practice Areas & Industries: Employee Benefits , Health and Welfare Benefit Plans , Tax
October 16, 2006	Whose Tax Law Is It? - Legal Times Type: Articles Author(s): Paul Devinsky Practice Areas & Industries: Intellectual Property , Tax
October 13, 2006	Technical Corrections in House Bill to the §954(c)(6) Look-Thru Exception - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Fall, 2006	Eighth Circuit Affirms Scherbart - TAXFAX Column of The Cooperative Accountant Type: Articles Author(s): George W. Benson Practice Areas & Industries: Cooperatives , Tax
Fall 2006	Final Section 199 Regulations - TAXFAX Column of The Cooperative Accountant Type: Articles Author(s): George W. Benson Practice Areas & Industries: Cooperatives , Tax
October 2006	Germany's never-ending tax reform: prospects for 2007/08 - Tax Directors Handbook 2007 - David Burgess Type: Articles Author(s): Gero Burwitz Practice Areas & Industries: Germany , Tax , Tax - Germany
September 22, 2006	Patents for tax strategies should be cause for concern - Boston Business Journal Type: Articles Author(s): Toby H. Kusmer PC Practice Areas & Industries: Intellectual Property , Patent Prosecution , Tax
9/11/06	To Practice Tax Law, You Need A Patent License - IP Law 360 Type: Articles Author(s): Paul Devinsky Practice Areas & Industries: Intellectual Property , Tax
Fall 2006	Code Sec. 954(c)(6) and the Same Country Rules for Sales and Services Income - JTGT Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: Tax
2003 - 2006	Financial Products: Taxation, Regulation and Design(Contributing author) Type: Books Author(s): Nathan F. Coco Practice Areas & Industries: Corporate , Finance & Banking , Tax
September/October 2006	ROTH 401(K)—IRS ISSUES GUIDANCE ON DISTRIBUTIONS, ROLLOVERS AND PLAN AMENDMENTS - Profit Sharing Magazine Type: Articles Author(s): Nancy S. Gerrie , Elizabeth A. Savard Practice Areas & Industries: Employee Benefits , Tax
September 2006	Recent Developments in International Taxation (United States) - International Bar Association, Taxation Section, National Reports Type: Articles Author(s): Practice Areas & Industries: Tax
August 11, 2006	New Subpart F Related CFC Look-Thru Exception - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
August 2006	IRS Updates Voluntary Correction Program - Employee Benefits News Type: Articles Author(s): Brett R. Johnson , Stephen R. Miller , Todd A. Solomon Practice Areas & Industries: Employee Benefits , Tax
2006	US Branch Report on the Attribution of Profits to Permanent Establishments - Cahiers de Droit Fiscal International of the International Fiscal Association Type: Articles Author(s): Steven P. Hannes Practice Areas & Industries: International Tax , Tax
2006	Virginia Limited Liability Company Forms and Practice Manual - Chapter 11, Tax Provisions Type: Other Author(s): Practice Areas & Industries: Insurance Companies and Products Tax , Tax
July 24, 2006	Roth 401(K)—IRS Issues Guidance on Distributions, Rollovers and Plan Amendments - Pension & Benefits Week Type: Articles Author(s): Nancy S. Gerrie , Elizabeth A. Savard Practice Areas & Industries: Employee Benefits , Tax
2006	Chapter 28, Critical Distinctions Between Weather Derivatives and Insurance - Structured Finance & Insurance: The ART of Managing Capital and Ris - John Wiley & Sons, Inc. Type: Books Author(s): Andrea S. Kramer Practice Areas & Industries: Energy Advisory , Energy Tax , Tax
July 14, 2006	Subpart F: LMSB Provides Guidance Concerning the Definition of Manufacturing - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
July 3, 2006	The Trend Toward Alternative Taxes and How They Are (or Must Be?) Apportioned - State Tax Notes Type: Articles Author(s): Practice Areas & Industries: State & Local Tax , Tax
2006	Chapter title:Credit Derivatives, Insurance, and CDO’s: The Aftermath of Enron - Structured Finance & Insurance: The ART of Managing Capital and Risk Type: Books Author(s): Andrea S. Kramer Practice Areas & Industries: Financial Products, Trading & Derivatives , Tax
June 7, 2006	Proposed §704(b) Regulations Create Excessive Burdens by Requiring that "Substantiality" Be Analyzed with Reference to Attributes of Indirect Partners - Tax Management Real Estate Journal Type: Articles Author(s): Philip Tingle Practice Areas & Industries: Real Estate - Tax , Tax
June 5, 2006	Not Everything Should Be Left to the Courts - State Tax Notes Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: State & Local Tax , Tax
June 2, 2006	Tax consequences of the migration of companies: a practitioner's perspective - EBOR (European Business Organization Law Review) Type: Articles Author(s): Gero Burwitz Practice Areas & Industries: International Tax , Tax
Summer 2006	Final Section 199 Regulations Support Taxpayer's Subpart F Contract Manufacturing Position - JTGT Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: Tax
May 15, 2006	LTR 200551018 and D Reorgs: The Debate Rages On - Tax Notes Type: Articles Author(s): Robert Feldgarden PC Practice Areas & Industries: Tax
May 12, 2006	Final §367 Regulations - A Fine-Tuned Version of the Proposed Regulations - Tax Management International Journal Type: Articles Author(s): Philip A. McCarty Practice Areas & Industries: International Tax , Tax
Spring 2006	Final Section 199 Regulations - TAXFAX Column of The Cooperative Accountant Type: Articles Author(s): George W. Benson Practice Areas & Industries: Cooperatives , Tax
May 2006	Illinois Income Tax Developments for COST Type: Other Author(s): Catherine A. Battin , Thomas H. Donohoe Practice Areas & Industries: State & Local Tax , Tax
March/April 2006	Proposed Regulatory Guidance Issued for Domestic Production Activities Deduction - International Transfer Pricing Journal Type: Articles Author(s): Gregory G. Palmer Practice Areas & Industries: International Tax , Tax
April 14, 2006	Contract Manufacturing Under Section 199: Implications for Subpart F - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
April 10, 2006	Should the States Determine Their Own Tax Destinies? Federalism in the 21st Century - Tax Analysts Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: State & Local Tax , Tax
March 2006	Current Strategies for Sharing IP Income Among Members of Multinational Groups: Cost Sharing Arrangements - Taxes — The Tax Magazine Type: Articles Author(s): Paul Dau Practice Areas & Industries: Tax , Transfer Pricing
March 2006	Alliances Not in Partnership or Corporate Form - CCH Inc. Type: Other Author(s): Gary C. Karch Practice Areas & Industries: Pass-Throughs , Tax
Spring 2006	CFC Loans to Foreign Partnerships Owned by U.S. Shareholders - JTGT Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
February 10, 2006	The Incongruent Definitions of Active Royalties for Subpart F and Foreign Tax Credit Purposes - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Winter 2006	New Asset Basis Adjustment Rules in Foreign Planning—Another Compliance Burden - Journal of Taxation of Global Transactions Type: Articles Author(s): James A. Riedy PC Practice Areas & Industries: International Tax , Tax
January 1, 2006	CFCs - Sections 959-965 and 1248 - BNA Tax Management Portfolio Type: Other Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
2006	Financing International Operations of U.S. Multinationals - PLI/Tax Tax Strategies for Corporate Acquisitions, Dispositions, Spin-offs, Joint Ventures, Financings, Reorganizations & Restructurings 2006 Type: Articles Author(s): Robert H. Dilworth Practice Areas & Industries: International Tax , Tax
2006	Look-through Treatment for Related Controlled Foreign Corporation Payments - CCH's Law, Explanation and Analysis of the Tax Increase Prevention and Reconcilation Act of 2005 Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
2006	The Sky Is Not Falling After Compaq: The Business Purpose Doctrine is Alive and Well in the Fifth Circuit - PLI/Tax Tax Strategies for Corporate Acquisitions, Dispositions, Spin-offs, Joint Ventures, Financings, Reorganizations & Restructurings 2006 Type: Articles Author(s): Robert H. Dilworth Practice Areas & Industries: Tax

2005

Date	Title
12/12/05	The Streamlined Sales Tax Project --And We're Off! - Tax Analysts Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
12/12/05	The Streamlined Sales Tax Project --And We're Off! - Tax Analysts Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
December 9, 2005	Notice 2005-64: §965 Qualifying Cash Dividends & Tax Computations - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Winter 2005	Computing the Section 965 Extraordinary Dividend - JTGT Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: Tax
November 11, 2005	Final & Prop. Regs. §1.951-1(e): U.S. Shareholders’ Pro Rata Share of Subpart F Income - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
October 31, 2005	New York Should Reconsider Its Policies on Temporary Residents - State Tax Today Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
October 14, 2005	2005 TTCA: Amendments to §965 - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Fall 2005	Dual Consolidated Loss Regulations—The Over-Under Bet and Selected Other Issues - Journal of Taxation of Global Transactions Type: Articles Author(s): Philip A. McCarty Practice Areas & Industries: International Tax , Tax
Fall 2005	The Proposed Cost Sharing Regulations: Conforming the Buy-in Rules to Current Audit Practice - Journal of Taxation of Global Transactions Type: Articles Author(s): Paul Dau Practice Areas & Industries: Tax , Transfer Pricing
2005	¶800 Temporary Incentive for Repatriation of Earnings Clarified - CCH's Law, Explanation and Analysis of the Hurricane Tax Relief Acts of 2005 Type: Other Author(s): Damon M. Lyon , Lowell D. Yoder Practice Areas & Industries: Tax
2005	¶805 Look-through Treatment for Sales of Partnership Interests Clarified - CCH's Law, Explanation and Analysis of the Hurricane Tax Relief Acts of 2005 Type: Other Author(s): Lowell D. Yoder Practice Areas & Industries: Tax
2005	United Kingdom - European Taxation Type: Articles Author(s): Peter M.W. Nias Practice Areas & Industries: International Tax , Tax
September 9, 2005	New Proposed Guidance on the Interaction of §§304 and 367--Issues and Unanswered Questions - Tax Management International Journal Type: Articles Author(s): Damon M. Lyon , Philip A. McCarty Practice Areas & Industries: International Tax , Tax
Fall 2005	Tidbits from Notice 2005-64 - JTGT Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: Tax
September / October 2005	U.S. Thin Capitalization Rules - IBFD Type: Articles Author(s): Damon M. Lyon , Lowell D. Yoder Practice Areas & Industries: Tax
August 22, 2005	Ohio's New Commercial Activity Tax -- To Pay or Not to Pay? - State Tax Notes (Tax Analysts) Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
2005	co-authored, Sales and Use Taxes: Streamlined Sales Tax System - BNA Tax Management Type: Books Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
August 12, 2005	Notice 2005-38: Applying §965 to Mergers and Acquisitions - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Mergers & Acquisitions , Tax
August 1, 2005	Comments on Multistate Tax Commission Proposed Model Statute for Addback of Certain Deductions - State Tax Notes Type: Articles Author(s): - Kimberley M. Reeder Practice Areas & Industries: State & Local Tax , Tax
July 8, 2005	Prop. Regs. §1.367(b)-4: Triangular Reorganization Rules Fixed - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
July/August 2005	Apportionment Apoplexy: Thow Back, Throw Out, or Just Throw Up Your Hands - The Tax Executive Type: Articles Author(s): Practice Areas & Industries: State & Local Tax , Tax
Summer 2005	The Buy-In Requirement for Cost Sharing Arrangements - Journal of Taxation of Global Transactions Type: Articles Author(s): Paul Dau Practice Areas & Industries: International Tax , Tax
June 15, 2005	The Marks & Spencer case - group taxation under review by the European Court of Justice - NZG Neue Zeitschrift für Gesellschaftsrecht Type: Articles Author(s): Dirk Pohl , Arndt Raupach Practice Areas & Industries: Germany , International Tax , Tax , Tax - Germany
June 2005	The Status of Tax Court Special Trial Judge Reports After Ballard - Journal of Taxation Type: Articles Author(s): Robin L. Greenhouse Practice Areas & Industries: Tax
May/June 2005	Federal Income Tax Benefit for Domestic Production Activities - International Transfer Pricing Journal Type: Articles Author(s): Gregory G. Palmer Practice Areas & Industries: International Tax , Tax , Transfer Pricing
Summer 2005	Notice 2005-38: Code Sec. 965 (b)(3)’s Related Party Indebtedness Rule - JTGT Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: Tax
2005	co-author chapter "Critical Distinctions Between Weather Derivatives and Insurance" - Structured Finance & Insurance: The ART of Managing Capital and Risk Type: Books Author(s): Andrea S. Kramer Practice Areas & Industries: Tax
May 9, 2005	Comments on the California FTB's Proposed Reg on Dividend Distribution - State Tax Notes Type: Articles Author(s): Practice Areas & Industries: State & Local Tax , Tax
Spring 2005 issue (vol. 44, no. 3)	Federal tax credit to promote wind generation - infrastructure Type: Articles Author(s): Martha Groves Pugh Practice Areas & Industries: Energy Tax , Tax
April 25, 2005	Coments on Multistate Tax Commission Proposed Model Statute for Combined Reporting - State Tax Notes Type: Articles Author(s): Practice Areas & Industries: State & Local Tax , Tax
2005	Group Finance Companies in International Tax Law with a supplementary analysis of Dublin-Docks-companies of German parent companies - Otto-Schmidt-Verlag Type: Books Author(s): Gero Burwitz Practice Areas & Industries: International Tax , Tax , Tax - Germany
April 18, 2005	Section 965: Temporary 85% DRD for CFC Dividends - Tax Management Memorandum Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: Tax
April 18, 2005	Who Proceeds and Who Succeeds: New Anti Morris trust Proposed Regulations - Tax Notes Today Type: Articles Author(s): Kevin Spencer Practice Areas & Industries: Tax , Tax Controversy
April 8, 2005	New Proposed §367 Regulations Address a Potpourri of Issues - Tax Management International Journal Type: Articles Author(s): Philip A. McCarty Practice Areas & Industries: Tax , Transfer Pricing
April 8, 2005	Notice 2005-10: Section 965 Cash Dividends and U.S. Investments - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
March 2005	EO Director Recruitment and Retention in a Post-Sarbanes World - The Exempt Organization Tax Review Type: Articles Author(s): Michael W. Peregrine Practice Areas & Industries: Nonprofit Organizations , Tax , Tax Exemption
March 2005	Tax and IP in the UK––Maximizing Use of IP Rights to Obtain Fiscal Advantages - Global Intellectual Property Asset Management Report Type: Articles Author(s): Practice Areas & Industries: Intellectual Property , Tax
March 2005	International Taxation: Re-Thinking Check-the-Box - TAXES: The Tax Magazine Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Spring 2005	JCT Recommends Classifying Foreign Disregarded Entities as CFCs: A Time Warped Idea - JTGT Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
February 11, 2005	Section 965: Technical Corrections Bill - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
January 2005	“Preventing Fraud and Deception, Part II” - The Risk Desk Type: Articles Author(s): Andrea S. Kramer Practice Areas & Industries: Financial Products, Trading & Derivatives , Tax

2004

Date	Title
December 13, 2004	Leading Practitioner Commentary on the International Tax Provisions of the American Jobs Creation Act of 2004 P.S. 108-357 CFC Changes - Tax Management Memorandum Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: Tax
December 10, 2004	Classification and Residence of Dually Chartered Entities - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Winter 2004	CFC Target: To Make or Not to Make a Code Sec. 338 Election - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
November 12, 2004	Prop. Regs.§1.951-1(e): Pro Rata Share of Subpart F Amounts Taxable to U.S. Shareholder - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder - Greg Walker Practice Areas & Industries: International Tax , Tax
November 2004	American Jobs Creation Act of 2004: Law, Explanation and Analysis - CCH Incorporated Type: Books Author(s): Gregory G. Palmer , Lowell D. Yoder Practice Areas & Industries: Tax
November, 2004	“Risk Control and Trading Employees: Preventing Fraud and Deception, Part I” - The Risk Desk Type: Articles Author(s): Andrea S. Kramer Practice Areas & Industries: Financial Products, Trading & Derivatives , Tax
2004	Risk Control and Trading Employees: Preventing Fraud and Deception - Chapter Excerpt from Derivatives accounting and Risk Management: Preventing Fraud and Deception Type: Books Author(s): Andrea S. Kramer Practice Areas & Industries: Tax
October 11, 2004	Withholding for Nonresidents: How Much Burden Should Employers Bear? - State Tax Notes Type: Articles Author(s): Practice Areas & Industries: State & Local Tax , Tax
October 8, 2004	Rev. Rul. 2004-77: The Classification of Single-Member Business Law - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
October 6, 2004	Asset Push-Ups - Practising Law Institute Course Handbook: Tax Strategies Type: Articles Author(s): Philip J. Levine Practice Areas & Industries: Tax , Tax - Acquisitions & Restructurings
September, 2004	IRS Targets Executive Compensation of Exempt Organizations - Employer's Guide to Fringe Benefits Rules Type: Articles Author(s): Bernadette M. Broccolo , Ralph E. DeJong Practice Areas & Industries: Employee Benefits , Executive Compensation , Health , Nonprofit Organizations , Tax , Tax Exemption
August 27 - September 2, 2004	Beware: IRS targeting exec compensation in audits - Boston Business Journal Type: Articles Author(s): Andrew C. Liazos Practice Areas & Industries: Executive Compensation , Tax
Fall 2004	Subpart F Related CFC Look-Through Exception Provided in Tax Bills Passed by Senate and House - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
August 13, 2004	Pre-Sale Branch Election for CFC Target: Dover v. Comr. Says No Subpart F Income - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
August, 2004	Developing Weather - Energy Risk Type: Other Author(s): Andrea S. Kramer Practice Areas & Industries: Financial Products, Trading & Derivatives , Tax
July 12, 2004	On H.R. 3320, the Business Activity Tax Simplification Act of 2003 - State Tax Notes (Tax Analysts) Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
June 11, 2004	Selling CFC Stock with a §338 Election: §1248 and Foreign Tax Credit Consequences - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
2004	Influence of European Law on International Tax - Publication in Honor of 50 Years of German Lawyers Institute Type: Articles Author(s): Arndt Raupach Practice Areas & Industries: Germany , International , Tax
June 2004	US Supreme Court Approves Challenging Unconstitutional State Tax Breaks in Federal Court - Practical US/Domestic Tax Strategies, Vol. 4, No. 6 Type: Articles Author(s): M. Miller Baker , William L. Goldman , Michael S. Nadel Practice Areas & Industries: State & Local Tax , Tax
Summer 2004	Senate Passes Tax Bill Without Contract Manufacturing Provision - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
May 2004	Weather Derivatives or Insurance? The Importance of an Accurate Designation - Futures and Derivatives Law Report Type: Articles Author(s): Andrea S. Kramer Practice Areas & Industries: Tax
May 31, 2004	Response to California Franchise Tax Board Analysis of H.R. 3320: The Federal; Business Activity Tax Bill Volume 32, No. 9 - State Tax Notes (Tax Analysts) Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
2004	Chapter 12: E-Commerce - Sales and Use Taxation Type: Books Author(s): Arthur R. Rosen Practice Areas & Industries: Tax , Tax - e-Business
May 2004	Weather Derivatives or Insurance? The Importance of an Accurate Designation - Risk Transfer Magazine Type: Articles Author(s): Andrea S. Kramer Practice Areas & Industries: Tax
April 9, 2004	Selling CFC Stock: Subpart F, Distributions and Calculating the §1248 Deemed Dividend - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
March 8, 2004	"Sarbanes-Oxeley and SALT: What Can Auditors Do? - State Tax Notes Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: State & Local Tax , Tax
Spring 2004	Tax Court Applies Penalties to Routine Foreign Tax Credit Planning Transaction - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
March/April 2004	What the Heck is a Digital Equivalent Anyway? - The Financial Manager Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
February 13, 2004	Sales and Services Income: Will There Ever Be Subpart F Legislative Reform? - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
February 2, 2004	"Is the Sky Really Falling?" - State Tax Notes Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
February 2004	Will Congress Answer the Hue and Cry? Is a CFC's Sale of a Partnership Interest Necessarily Passive Subpart F Income? - The M&A Tax Report Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: Mergers & Acquisitions , Tax
January - February 2004	"Dividend Relief with Uncertainties for High-Net-Worth Taxpayers" - Journal of Retirement Planning Type: Articles Author(s): Andrea S. Kramer , William R. Pomierski Practice Areas & Industries: Private Equity , Tax
2004	Financing of medium seized businesses in the shadow of the new German thin-capitalization rules (Para. 8a Corporation tax act) - Anwaltspraxis Wirtschaftsrecht Type: Articles Author(s): Gero Burwitz Practice Areas & Industries: International Tax , Tax , Tax - Germany
2004	The Supreme Court and State Taxation: 2002-2003, A Verdict on the Continuing Viability of Equal Protection for Business - The State and Local Tax Lawyer - ABA Type: Books Author(s): Practice Areas & Industries: State & Local Tax , Tax

2003

Date	Title
December 12, 2003	CFC Sale of an Interest in a Partnership: A Legislative Fix Is Imperative - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
December 11-12, 2003	Application of Tax Shelter Rules to International Transactions - George Washington University/IRS 16th Annual Institute on Current Issues in International Taxation Type: Articles Author(s): Robert H. Dilworth Practice Areas & Industries: International Tax , Tax
November 15, 2003	New York State Withholding Tax Audit Initiative - Multistate Tax Analyst* (vol. 14, No. 4)* Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
November 3, 2003	New York's Employment Withholding Tax Audit Initiative - Not Missing a Trick (or a Trip) - State Tax Notes Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
October 31, 2003	State Tax Withholding Audit Initiative Examined - Inside New York Taxes* (vol. 13, No. 5)* Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
October 10, 2003	Check-and-Sell Transactions: Proposed Regulations Withdrawn, But Still Under Attack - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder - Sheri L. Everson Practice Areas & Industries: International Tax , Tax
October 10, 2003	Foreign-to-Foreign Liquidations No Longer Subject to §367 Anti-Abuse Rule - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Fall 2003	“Netting Nonpatronage Losses Against Patronage Income — A Footnote,” - The Cooperative Accountant Magazine Type: Articles Author(s): George W. Benson Practice Areas & Industries: Tax
Fall 2003	“Tax Planning for Cyclical or Other Temporary Losses - UK Response,” - Tax Management International Forum 2003 - III Type: Articles Author(s): Peter M.W. Nias Practice Areas & Industries: London , Tax , Tax - London
September 8, 2003	“New York’s ‘Convenience of Employer’ Doctrine Extended in Unterweiser,” - State Tax Notes Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: State & Local Tax , Tax
Fall 2003	Proposed Check-and-Sell Regulations Withdrawn - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Fall 2003	Tax Beneficial Structures for Acquiring European Targets - European CEO Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
August 11, 2003	“Planning is Not ‘Sheltering’: A Practitioner’s Response to the MTC,” - State Tax Notes Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: State & Local Tax , Tax
August 8, 2003	Subpart F Repatriation: Distribution Timing is Everything - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
July 21, 2003	"Intangible Holding Companies Set Back in Maryland and New York," - State Tax Notes Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: State & Local Tax , Tax
July 7, 2003	“Worldwide Apportionment of Interest Revisited,” - Tax Notes International Type: Articles Author(s): Steven P. Hannes , James A. Riedy PC Practice Areas & Industries: International Tax , Tax
July 2003	State Tax Considerations in Choosing a Pass-Through Entity Form of Business - Journal of Multistate Taxation and Incentives Type: Articles Author(s): Practice Areas & Industries: State & Local Tax , Tax
Summer 2003	New York's "Critical Element" Test Extends Beyond Resale to the Drugs Exemption, for Components of Free Samples - Institute for Professionals in Taxation Sales Tax Report Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: Tax , Tax Exemption
Summer 2003	New York's "Critical Element" Test Extends Beyond Resale to the Drugs Exemption, for Components of Free Samples - IPT Sales Tax Report Type: Articles Author(s): Arthur R. Rosen Practice Areas & Industries: State & Local Tax , Tax
Summer 2003	“Can Your Cooperative Benefit from the Enhanced Bonus Depreciation and Section 179 Expensing Provisions in the New Tax Act?,” - Mississippi Valley Chapter of the NSAC Newsletter Type: Articles Author(s): George W. Benson Practice Areas & Industries: Tax
2003	“State Taxation of Intellectual Property,” - 2003 NYU Institute on State and Local Taxation Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: State & Local Tax , Tax
June 13, 2003	Subpart F Hopscotch Rule Permits Targeted Repatriation - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Summer 2003	Tax Beneficial Finance Structures for Acquiring Foreign Targets - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
June 9, 2003	Viewpoint: Moran Towing Leaves Transactional Nexus a Sinking Ship in New York - State Tax Notes Type: Articles Author(s): Practice Areas & Industries: State & Local Tax , Tax
2003	Structuring after the elimination of fiscal unity with several parents (Mehrmütterorganschaft) - DStR Type: Articles Author(s): Gero Burwitz , Arndt Raupach Practice Areas & Industries: Germany , International , Tax
June 2, 2003	"Sherwin-Williams Represents Sound Intellectual Property law - Not a Flawed Decision" - State Tax Notes Type: Articles Author(s): Margaret M. Duncan , Peter L. Faber Practice Areas & Industries: Intellectual Property , State & Local Tax , Tax
June 2003	co-author chapter 12 “Credit Derivatives Post-Enron" - Corporate Aftershock: Public Policy Lessons from the Collapse of Enron & other Corporations* - John Wiley & Sons, Inc.* Type: Books Author(s): Andrea S. Kramer Practice Areas & Industries: Tax
June 2003	co-author chapter 3 “Corporate Governance: Pre-Enron, Post-Enron" - Corporate Aftershock: Public Policy Lessons from the Collapse of Enron & other Corporations* - John Wiley & Sons, Inc.* Type: Books Author(s): Andrea S. Kramer Practice Areas & Industries: Tax
June 2003	co-author chapter 5, “Regulation of Electricity Trading After Enron,” - Corporate Aftershock: Public Policy Lessons from the Collapse of Enron & other Corporations* - John Wiley & Sons, Inc.* Type: Books Author(s): Andrea S. Kramer Practice Areas & Industries: Tax
May 31, 2003	"UK Tax Relief for R&D" - Practice US/International Tax Strategies Type: Articles Author(s): Peter M.W. Nias Practice Areas & Industries: International , International Tax , London , Tax , Tax - London
May 12, 2003	“Achieving Transfer Pricing Objectives Without Creating a U.S. Business for a Foreign Person” - Tax Notesi> Type: Articles Author(s): Steven P. Hannes Practice Areas & Industries: International Tax , Tax
April 11, 2003	Final Brown Group Regs.: Aggregate/Entity Duplicity - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Spring 2003	Structures that Reduce Source Country Taxes - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
March 17, 2003	“Pennsylvania Commonwealth Court: Section 338(h)(10) Gain is Nonbusiness Income,” - State Tax Notes Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: State & Local Tax , Tax
March 14, 2003	Final Regulations Apply Subpart F to a CFC's Distributive Share of Partnership Income - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
March 2003	From Storefronts to Servers to Service Providers: Stretching the Permanent Establishment Definition to Accomodate New Business Models - Taxes Type: Articles Author(s): Sandra P. McGill , Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
February 14, 2003	Look-Through For 10/50 Joint Venture Corporations: Not a Panacea - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
Winter 2003	The Limited Case: A Refresher in Statutory Interpretation - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
2000 to 2003	New Jersey Chapter - Sales and Use Tax Deskbook - ABA Type: Books Author(s): Practice Areas & Industries: State & Local Tax , Tax

2002

Date	Title
December 9, 2002	Use of Intangible Company Upheld as Business Reorganization: Massachusetts Gets It Right in Sherwin-Williams - State Tax Notes Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: State & Local Tax , Tax
Winter 2002	Temporary and Proposed Regulations Change Definition of ‘Reportable Transactions - The Cooperative Accountant Type: Articles Author(s): George W. Benson Practice Areas & Industries: Tax
2002	"Overview of Global Regulation" (co-author) - Global Reinsurance- Special Report: Cayman Islands Type: Articles Author(s): Thomas M. Jones PC Practice Areas & Industries: Insurance , Insurance Companies and Products Tax , Tax
October 2002	"The Service's Tax Shelter Disclosure Initiative: What Has Become of Evidence?" - Journal of Taxation Type: Articles Author(s): Robin L. Greenhouse , Michael F. Kelleher Practice Areas & Industries: Tax
Fall 2002	No Issues Peculiar to Subchapter T Cooperatives Included on the 2002-2003 Priority Guidance Plan - The Cooperative Accountant Type: Articles Author(s): George W. Benson Practice Areas & Industries: Tax
Fall 2002	Final Regulations Address CFC Partner/Partnership Transactions - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
September 13, 2002	The Limited, Inc. v. Comr.: Appellate Court Slams Tax Court's Narrow Interpretation of §956 Bank Deposits Exception - Tax Management International Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: Tax
September 2002	"Growing Burdens on Offshore Regulators" - Captive Insurance Company Reports Type: Articles Author(s): Thomas M. Jones PC Practice Areas & Industries: Insurance , Insurance Companies and Products Tax , Tax
September 2002	Digest of Recent Cooperative Tax Developments - NSAC Mississippi Valley Chapter Newsletter Type: Articles Author(s): George W. Benson Practice Areas & Industries: Tax
September 2002	co-author, "Host Country Tax Consequences of Engaging in a Sale-Repurchase Transaction Using Host Country Securities" - Tax Management International Forum Type: Articles Author(s): Peter M.W. Nias Practice Areas & Industries: International , International Tax , London , Tax , Tax - London
August 29, 2002	co-author, "A Major Power Cut" - Taxation,* Vol. 149, No. 3872* Type: Articles Author(s): Peter M.W. Nias Practice Areas & Industries: Tax
August 2002	"IRS Approves New Health Plan Design," - Complying with IRS Employee Benefits Rules Type: Articles Author(s): Susan M. Nash Practice Areas & Industries: Tax
July 29, 2002	Sweeping Changes in Corporate Taxes - New Jersey Law Journal Type: Articles Author(s): Practice Areas & Industries: State & Local Tax , Tax
July 2002	"Tax Rules Proposed for Split-Dollar Life Insurance Arrangements" - Practical US/Domestic Tax Strategies,* Vol. 2, No. 7* Type: Articles Author(s): Peter L. Faber , David A. Herpe , Andrew C. Liazos Practice Areas & Industries: Executive Compensation , Tax
2002	Chapter, Weather Derivatives or Insurance? Considerations for Energy Companies - The A.R.T. of Risk Management - John Wiley & Sons, Inc. Type: Books Author(s): Andrea S. Kramer Practice Areas & Industries: Energy Advisory , Energy Tax , Tax
2002	The reform of the corporate income tax system, in: perspectives of company taxation - DStJG Type: Articles Author(s): Arndt Raupach Practice Areas & Industries: Germany , International , Tax
June 14, 2002	The Subpart F Exception for Active Financing Income - Tax Management International Journal Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
June 2002	"New Hedging Regulations Guidance for U.S. Taxpayers" - FOW Type: Articles Author(s): Andrea S. Kramer , William R. Pomierski Practice Areas & Industries: Financial Products, Trading & Derivatives , Tax
Summer 2002	The Finance Company Exception to Subpart F - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries: International Tax , Tax
May 13, 2002	"Business Purpose & the Syms Case in Massachusetts - The Interplay of Federal & State Tax Concepts" - State Tax Notes Type: Articles Author(s): Peter L. Faber Practice Areas & Industries: State & Local Tax , Tax
Spring 2002	The Export Tax Incentive Is Not Dead Yet - Journal of Taxation of Global Transactions Type: Articles Author(s): Lowell D. Yoder Practice Areas & Industries:

Articles & Books

2012

Ripartizione del cinque per mille

Riscossione coattiva e Convenzione europea dei diritti dell'uomo: alcune reflessioni

The New York Residency Wars Continue: Year-End Rulings

2011

The Tax Department's Role in Sustainable Transfer Pricing

Designing a Territorial Tax System for the United States

Taxation and Accounting XVI

Two for One: How the NCAA Rules Do Not Adequately Address Package Deals and a Proposed Rule to Prohibit Them

Swap Assignments Safe Harbor Extended in Anticipation of Dodd-Frank Implementation

Clarification on Requirements for Dividend-Withholding Tax Reimbursements in Italy

Taxing the profits from patents in the UK - boxing clever

Solidarità doppia per i manager: Dirigenti e collaboratori del settore finanziario scontano anche l'addizionale Irpef sui bonus

Clarification on Requirements for Dividend-Withholding Tax Reimbursements in Italy

Someone Might Sue N.Y. to Collect More Taxes from Your Company

Real Estate & Passthrough Finance Techniques Corner: "IRS Stretches to Help a Taxpayer in New Disguised Sale Private Letter Ruling"

Navigating the Accounting Method Change Landscape - The New §381 Regulations and Other Developments

2010

U.S.--IRS Denies Tax Deferral and Long- Term Capital Gains through Basket Option Transaction

One Member Cooperative Subsidiary of a Rural Electric Cooperative Qualified as a Cooperative

Small Business Jobs Act of 2010: Cost Recovery Provisions of Interest to Cooperatives

IRS Releases Final Schedule UTP and Instructions

UK Corporate Tax Update

Cooperative Tax Developments

Tax Highlights

The current provision in the German annual taxation act

New Protocol to Barbados-China Double Tax Agreement Enters into Force

Does Section 263A Apply to Grain Inventories Valued at Market?

Illinois Law Change Affecting Use of Losses

CFCs--General Overview, 926-3rd T.M.

Transfer Pricing Discussion Group's Comments on IRS Schedule UTP

Credit Unions Prevail in Bellco Case, Section 199 Developments, & Ethanol Developments

ECJ Ruling on Italian Dividend Withholding Tax: Analysis and Ramifications

Where We've Been and Where We're Going—Taking Stock

State RAR Reporting—Simplifying Unnecessary Complexities

Tax Havens and Tax Policy: How Should the U.S. Tax System Treat Income Earned by Multinationals in Low-Tax Jurisdictions?

Section 199 & Grain Marketing Cooperatives Winter Newsletter

Corporation Business Tax Chapter; Sales & Use Tax Chapter

Putting the ‘Fair’ Back in Fair Apportionment

G-I Holdings: A Court Finally Speaks on Partnership Disguised Sales of Property, but Should Anyone Listen?

Partnership Disguised Sales: G-I Holdings Misses the Mark

SALT Shaker Newsletter

2009

Unclaimed Property Administration—Taking Advantage of Uncertainty

Quarterly Column

States Attempt to Seize Class Action Settlements as Unclaimed Property

As Finalized, Section 362(e)(2) Does Not Apply to Intercompany Transactions, Unless It Does

Sogg v. Zurz: Unclaimed Property—Do You Own Your Income?

Chapter 9: Appeals

Chapter: Never Thought I'd Be a Constitutional Lawyer

Commentary on Sec. 24 and 25 German Corporate Income Tax Code

Industry Comment Column

IRS Issues Initial Guidance and Limited Transition Relief for Nonqualified Deferred Compensation Plans Subject to New Section 457A

Tax Highlights

Vondjidis v. Hewlett Packard: Sacrificing Good Unclaimed Property Policy In Search of Perfect Compliance?

Cancellation of Indebtedness Income Deferral in Economic Stimulus Bill Raises Complex Issues for Partnerships

New COD Income Deferral Guidance Provides Flexibility for Partnerships

New Cancellation of Indebtedness Income Deferral in Economic Stimulus Bill

Recent Developments in Partnership Taxation