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Insights & Commentary

The following are selected comments by leading tax authorities on a variety of current tax issues. Extensive collections of current commentary are contained in BNA Tax Management’s news publications and specialized journals.

Recent Additions
> Your Expense Disallowed and a Constructive Dividend Too - But With Current Low Rates It Won’t Be So Bad for You, By Gerald S. Deutsch, Esq....November 2008
> Planning to Maximize Use of Suspended Losses in Connection with Disposition of S Corporation Stock, By Donald T. Williamson, CPA...October 2008
> Emergency Economic Stabilization Act of 2008 and Related Developments - an Employee Benefits Update, By Jennifer Eller, Esq....October 2008
> Update Regarding State Conformity With The Federal Domestic Production Deduction, By Michael H. Salama, Esq. and Brandee A. Tilman, Esq.....October 2008
> Reportable Transactions, By Todd Simmens and James Hartford....October 2008
> When Are Gains from Trading Securities Effectively Connected to a Banking Business? TAM 200811018 Provides Some Conclusions, But No Analysis, By Kimberly S. Blanchard, Esq.....October 2008
> New Relief for Failure to File No-Withholding FIRPTA Certificates: Secret Law?, By Kenneth J. Krupsky, Esq.....October 2008
> The Continuing Saga of the U.S.-Canada Protocol: The Senate Foreign Relations Committee Adds a Condition, By David R. Tillinghast, Esq.....October 2008
> Tax Treatment of Scholarships and Fellowships Awarded to Resident Aliens, By Bertrand M. Harding, Jr., Esq.....October 2008
> Commentary: New “Guide Sheets” on Supporting Organizations, By Gerald B. Treacy, Jr., Esq.....October 2008
> Private Annuities after Proposed Regulations §§1.72-6(e) and 1.1001-1(j), By Edward P. Wojnaroski, Jr., Esq., M.S. (Tax), CFP®....October 2008
> IRS Offers a “Take It or Leave It” for Corporations Engaged in SILO and LILO Transactions, By Lisa Starczewski, Esq....October 2008
> Proposed Regulations Set Forth Substantiation and Reporting Requirements for Charitable Contributions, By Carol A. Kelley, Esq....September 2008
> IRS Releases Certain Debt Instruments from AHYDO Grip, By Steven D. Bortnick, Esq. and Marc D. Nickel, Esq....September 2008
> Taxation of Debt Instruments -- What Needs To Be Done, By Yoram Keinan, MPA, ITP, LL.M., SJD...September 2008
> Intangible Drilling Costs -- Year of Deduction, By Professor Richard A. Westin...September 2008
> The New Expatriation Tax Regime - §877A, By Edward Tanenbaum, Esq....September 2008
> Foreign Subsidiary's Acquisition of a Foreign Target with U.S. Parent Stock, By Lowell D. Yoder, Esq....September 2008
> The Protocol to the U.S.-Canada Income Tax Treaty, By Willard B. Taylor, Esq....September 2008
> Section 956 Relief for Certain Partnerships, By Philip D. Morrison, Esq....September 2008
> Practitioners' Forum Discussion: Proposed Regulations Regarding Participant Disclosures, 73 Fed. Reg. 43014 (July 23, 2008), By Janine H. Bosley, Anna Driggs, Louis T. Mazawey, and William F. Sweetnam, Jr....September 2008
> Recent PLR Provides Insight Into the Treatment of Transaction Costs, By Ellen McElroy, Esq....September 2008
> Community Property vs. Innocent Spouse Relief - No Refund, By Kathleen Ford Bay...September 2008
> The Application of the Built-In Gains Tax May Result in Greater Liability than if S Election Not Made, By Donald T. Williamson, CPA....September 2008
> Half the Deduction Must Be Lost - But Will the Lessee or Lessor Bear the Cost? Rev. Rul. 2008-23, By Gerald S. Deutsch, Esq....September 2008
> IRS Updates Qualified Plan Correction Program, By Joseph Adams, Paul M. Hamburger, Brett R. Johnson and Stephen R. Miller...September 2008
> Minimum Funding: What if Technical Corrections Passes? Or Doesn't?, By Lynn A. Cook, Esq....September 2008
> Gains from the Sale of EU Carbon Emission Allowances Not Treated as Subpart F Income, By David R. Tillinghast, Esq....August 2008
> District Court Clarifies Standard for Providing Notice of Plan Limitations Provisions, By Michael T. Graham and Joanna C. Enstice...August 2008
> Timber Investments for Foreigners and the New Component of Section 631(b), By Professor Richard A. Westin...August 2008
> Inconsistent Application of the Attribution Rule, By Professor Karen B. Brown...August 2008
> Capitalization of Prepaid IDCs: The Government Position on Audit, By Professor Richard A. Westin...August 2008
> Special Allocations of Percentage Depletion, By Professor Richard A. Westin...August 2008
> IRS Rules That Wall Street Cannot Buy Your Company's Pension Plan--Yet, By Michael G. Kushner, Esq....August 2008
> You've Got to Have HEART -- Except for Green Card Holders, By James J. Tobin, Esq....August 2008
> New §956 Regulations: Shoot First, No Comments Later, Please!, By Kenneth J. Krupsky, Esq....August 2008
> FIRPTA in the 21st Century, Installment Five: §897(h)(1) and Tiered REIT Liquidations, By Kimberly S. Blanchard, Esq....August 2008
> Proposed Intercompany Obligations Regulations , By George L. White, Esq....August 2008
> Current Initiatives by IRS to Assist Small Employers that Adopt Pre-Approved Qualified Retirement Plan Documents, By Barry Kozak, Esq....August 2008
> Reporting and Disclosure Issues With Small Employer Employee Benefit Plans, By Barry Kozak, Esq....August 2008
> Valuation of Restricted Management Account Gifts for Gift Tax Purposes, By William P. Streng, Vinson & Elkins Professor of Law...August 2008
> The Fiduciary Corner: Rollovers to Plan Service Providers Present Fiduciary Concerns, By Gregory L. Ash...August 2008
> The F Reorganization -- Too Small to Fail?, By Michael J. Kliegman, Esq....August 2008