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2008

Date Title
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

May 26, 2008

Setting the Record Straight on the Business Activity Tax Simplification Act

- State Tax Notes
Type: Articles
Author(s): Jeffrey S. Reed , Arthur R. Rosen
Practice Areas & Industries: State & Local Tax , Tax

May 2008

As Transit Benefit Popularity Grows, Employers Have Questions

- Employers Guide to Fringe Benefit Rules
Type: Articles
Author(s): David R. Fuller
Practice Areas & Industries: Employee Benefits & Pensions , Fringe Benefits , 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 2008 / June 2008

Proposed Subpart F Contract Manufacturing Regulations

- International Tax Journal
Type: Articles
Author(s): Lowell D. Yoder
Practice Areas & Industries: International Tax , Tax

April 14, 2008

Stop the State Tax Grab

- Legal Times
Type: Articles
Author(s): Jeffrey S. Reed , Arthur R. Rosen
Practice Areas & Industries: State & Local 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

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

February 2008

States Enforcing Other States' Judgments Are Just Following the Constitution

- Tax Analysts
Type: Articles
Author(s): Jeffrey S. Reed
Practice Areas & Industries: State & Local Tax , Tax

January 2008

Foreign Tax Credits

- International Tax Journal
Type: Articles
Author(s): James A. Riedy PC
Practice Areas & Industries: Tax

January 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

Be Careful Out There: The IRS Has Lawyers in its Cross-Hairs

- Orange County Lawyer
Type: Articles
Author(s): Elliot Silverman
Practice Areas & Industries: Tax , Tax Controversy

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 , Justin Hill Ph.D.
Practice Areas & Industries: Intellectual Property, Media & Technology , 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

2007

Deductibility of Bribes, Kickbacks, Illegal Payments, Fines, and Penalties

- Tax Management Portfolio 524 (BNA)
Type: Articles
Author(s): Thomas D. Sykes
Practice Areas & Industries: Tax , Tax Controversy

2008

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

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 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

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

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 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

August 24, 2007

Irrationality, Inconsistency, and Discrimination: Why New Jersey’s Throw-Out Rule Is Unconstitutional

- Multistate Tax Report
Type: Articles
Author(s): Leah Samit
Practice Areas & Industries: State & Local 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

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 , Tax , Tax Exemption

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 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

“Credit Risk Management in the European Day-Ahead Power Markets,”

- Futures Industry
Type: Articles
Author(s): Doron F. Ezickson , 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 and Derivatives Markets , 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 , Katherine Stenander
Practice Areas & Industries: International Tax , Tax

March 2007

Energy Trading Law, Part II

- The Risk Desk
Type: Articles
Author(s): Andrea S. Kramer
Practice Areas & Industries: Energy and Derivatives Markets , 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

February, 2007

New Book: Energy Trading Law

- The Risk Desk
Type: Articles
Author(s): Andrea S. Kramer
Practice Areas & Industries: Energy and Derivatives Markets , Energy Tax , Tax

February 2007

IRS Grounds High-Flying Corporate Assets

- Employers Guide to Fringe Benefit Rules
Type: Articles
Author(s): David R. Fuller
Practice Areas & Industries: Aircraft Acquisition and Operation , Private Client , 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): David R. Fuller , Susan M. Nash
Practice Areas & Industries: Employee Benefits & Pensions , 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

2006

Editors: Susan Nash, David Fuller

- Employers' Handbook: Complying With IRS Employee Benefits Rules
Type: Articles
Author(s): David R. Fuller , Susan M. Nash
Practice Areas & Industries: Employee Benefits & Pensions , Tax

December 2006

Establishing a Qualified Transportation Fringe Benefit Program

- Employer's Guide to Fringe Benefit Rules
Type: Articles
Author(s): David R. Fuller , Jerry E. Holmes
Practice Areas & Industries: Fringe Benefits , 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

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

8th Circuit Reverses Transport Labor Decision

- Fringe Benefit Rules
Type: Articles
Author(s): David R. Fuller
Practice Areas & Industries: Fringe Benefits , 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 Enstice , Todd A. Solomon
Practice Areas & Industries: Employee Benefits & Pensions , Tax , Welfare Benefit Plans

October 16, 2006

Whose Tax Law Is It?

- Legal Times
Type: Articles
Author(s): Paul Devinsky , John R. Fuisz , Thomas D. Sykes
Practice Areas & Industries: Intellectual Property, Media & Technology , Tax

Fall 2006

Additional Adjustments in the Wake of a Transfer Pricing Adjustment - UK Response

- Tax Management International Forum 2006 - III
Type: Articles
Author(s): Nicola Purcell
Practice Areas & Industries: Tax , Transfer Pricing

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, Media & Technology , Patent Prosecution , Tax

9/11/06

To Practice Tax Law, You Need A Patent License

- IP Law 360
Type: Articles
Author(s): Paul Devinsky , John R. Fuisz , Thomas D. Sykes
Practice Areas & Industries: Intellectual Property, Media & Technology , 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 2006

New Flexibility Under Final Regs. Affecting Foreign-Law Mergers and Section 367

- Journal of Taxation
Type: Articles
Author(s):
Practice Areas & Industries: International Tax , Tax

September-October 2006

New Texas “Margin Tax” Will Apply to Most Passthrough Entities

- Journal of Passthrough Entities
Type: Articles
Author(s):
Practice Areas & Industries: State & Local Tax , 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 & Pensions , Tax

September 2006

Recent Developments in International Taxation (United States)

- International Bar Association, Taxation Section, National Reports
Type: Articles
Author(s): John G. Ryan
Practice Areas & Industries: Tax

September 2006

US Tax Shelters--Recent Developments

- PLC Cross Border Quarterly
Type: Articles
Author(s): Holly K. Hemphill
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 & Pensions , 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): Mark A. Opper
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 & Pensions , 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 and Derivatives Markets , Energy Tax , Tax

July 2006

Do Your Executive Perks Quack Like a Duck?

- Employer’s Guide to Fringe Benefit Rules
Type: Articles
Author(s): David R. Fuller
Practice Areas & Industries: Fringe Benefits , Tax

July 2006

Final Regulations: Section 367 Does not Apply to Deemed Section 351 Exchanges in Section 304(a)(1) Transactions

- Journal of International Taxation
Type: Articles
Author(s):
Practice Areas & Industries: International Tax , Tax

July 2006

US Tax Shelters--Recent Developments

- PLC Cross Border
Type: Articles
Author(s): Holly K. Hemphill
Practice Areas & Industries: