The following are selected comments by leading tax authorities on a variety of current tax issues. Extensive collections of current commentary are contained in BNA Tax Management’s news publications and specialized journals.
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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 |
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Planning to Maximize Use of Suspended Losses in Connection with
Disposition of S Corporation Stock,
By Donald T. Williamson,
CPA...October 2008 |
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Emergency Economic Stabilization Act of 2008 and Related
Developments - an Employee Benefits Update,
By Jennifer Eller,
Esq....October 2008 |
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Update Regarding State Conformity With The Federal Domestic
Production Deduction,
By Michael H. Salama, Esq. and Brandee A. Tilman,
Esq.....October 2008 |
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Reportable Transactions,
By Todd Simmens and James
Hartford....October 2008 |
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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 |
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New Relief for Failure to File No-Withholding FIRPTA Certificates:
Secret Law?,
By Kenneth J. Krupsky,
Esq.....October 2008 |
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The Continuing Saga of the U.S.-Canada Protocol: The Senate
Foreign Relations Committee Adds a Condition,
By David R. Tillinghast,
Esq.....October 2008 |
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Tax Treatment of Scholarships and Fellowships Awarded to Resident
Aliens,
By Bertrand M. Harding, Jr.,
Esq.....October 2008 |
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Commentary: New “Guide Sheets” on Supporting
Organizations,
By Gerald B. Treacy, Jr.,
Esq.....October 2008 |
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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 |
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IRS Offers a “Take It or Leave It” for Corporations Engaged in SILO and LILO Transactions,
By Lisa Starczewski, Esq....October 2008 |
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Proposed Regulations Set Forth Substantiation and Reporting
Requirements for Charitable Contributions,
By Carol A. Kelley, Esq....September 2008 |
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IRS Releases Certain Debt Instruments from AHYDO Grip,
By Steven D. Bortnick, Esq. and Marc D. Nickel,
Esq....September 2008 |
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Taxation of Debt Instruments -- What Needs To Be Done,
By Yoram Keinan, MPA, ITP, LL.M.,
SJD...September 2008 |
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Intangible Drilling Costs -- Year of Deduction,
By Professor Richard A.
Westin...September 2008 |
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The New Expatriation Tax Regime - §877A,
By Edward Tanenbaum,
Esq....September 2008 |
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Foreign Subsidiary's Acquisition of a Foreign Target with U.S.
Parent Stock,
By Lowell D. Yoder,
Esq....September 2008 |
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The Protocol to the U.S.-Canada Income Tax Treaty,
By Willard B. Taylor,
Esq....September 2008 |
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Section 956 Relief for Certain Partnerships,
By Philip D. Morrison,
Esq....September 2008 |
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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 |
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Recent PLR Provides Insight Into the Treatment of Transaction
Costs,
By Ellen McElroy, Esq....September 2008 |
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Community Property vs. Innocent Spouse Relief - No Refund,
By Kathleen Ford Bay...September 2008 |
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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 |
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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 |
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IRS Updates Qualified Plan Correction Program,
By Joseph Adams, Paul M. Hamburger, Brett R. Johnson and Stephen
R. Miller...September 2008 |
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Minimum Funding: What if Technical Corrections Passes? Or
Doesn't?,
By Lynn A. Cook, Esq....September 2008 |
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Gains from the Sale of EU Carbon Emission Allowances Not Treated
as Subpart F Income,
By David R. Tillinghast,
Esq....August 2008 |
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District Court Clarifies Standard for Providing Notice of Plan
Limitations Provisions,
By Michael T. Graham and Joanna C.
Enstice...August 2008 |
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Timber Investments for Foreigners and the New Component of Section
631(b),
By Professor Richard A.
Westin...August 2008 |
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Inconsistent Application of the Attribution Rule,
By Professor Karen B. Brown...August 2008 |
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Capitalization of Prepaid IDCs: The Government Position on
Audit,
By Professor Richard A.
Westin...August 2008 |
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Special Allocations of Percentage Depletion,
By Professor Richard A.
Westin...August 2008 |
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IRS Rules That Wall Street Cannot Buy Your Company's Pension
Plan--Yet,
By Michael G. Kushner, Esq....August 2008 |
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You've Got to Have HEART -- Except for Green Card Holders,
By James J. Tobin, Esq....August 2008 |
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New §956 Regulations: Shoot First, No Comments Later,
Please!,
By Kenneth J. Krupsky, Esq....August 2008 |
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FIRPTA in the 21st Century, Installment Five: §897(h)(1) and
Tiered REIT Liquidations,
By Kimberly S. Blanchard, Esq....August 2008 |
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Proposed Intercompany Obligations Regulations ,
By George L. White, Esq....August 2008 |
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Current Initiatives by IRS to Assist Small Employers that Adopt
Pre-Approved Qualified Retirement Plan Documents,
By Barry Kozak, Esq....August 2008 |
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Reporting and Disclosure Issues With Small Employer Employee
Benefit Plans,
By Barry Kozak, Esq....August 2008 |
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Valuation of Restricted Management Account Gifts for Gift Tax
Purposes,
By William P. Streng, Vinson & Elkins Professor of
Law...August 2008 |
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The Fiduciary Corner: Rollovers to Plan Service Providers Present
Fiduciary Concerns,
By Gregory L. Ash...August 2008 |
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The F Reorganization -- Too Small to Fail?,
By Michael J. Kliegman,
Esq....August 2008 |