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Your search criteria matched 189 items:

Notice 2008-84
Restructuring Troubled Companies
Lisa Zarlenga
September 26, 2008
Consolidated Return Loss Disallowance and Loss Duplication Rules
Mark Silverman, Lisa Zarlenga
September 25, 2008
Continuity of Interest and Continuity of Business Enterprise Regulations
Mark Silverman
September 25, 2008
Corporate Divisions Under Section 355
Mark Silverman
September 25, 2008
Current Developments in Tax-Free Corporate Reorganizations
Mark Silverman
September 25, 2008
Final Section 355(e) Plan Regulations – The Final chapter in the Saga
Mark Silverman, Lisa Zarlenga
September 25, 2008
Intercompany Transaction Problems
Mark Silverman
September 25, 2008
Recent Developments in the Step Transaction Doctrine
Mark Silverman
September 25, 2008
Regulations Governing Intercompany Transactions Within Consolidated Groups
Mark Silverman
September 25, 2008
Section 355(d) Regulations: Narrowing the Scope of an Overly Broad Statute
Mark Silverman, Lisa Zarlenga
September 25, 2008
Section 382 Consolidated Return Regulations
Mark Silverman
September 25, 2008
Spin-Offs: The Anti-Morris Trust and Intragroup Spin Provisions
Mark Silverman, Lisa Zarlenga
September 25, 2008
The Fourth Time’s a Charm-- Temporary Section 355(e) Regulations Provide Helpful Guidance to Taxpayers
Mark Silverman, Lisa Zarlenga
September 25, 2008
The Pre-Reorganization Continuity of Interest Regulations
Mark Silverman
September 25, 2008
Who Precedes and Who Succeeds: Proposed Section 355(e)(4)(d) Regulations (article)
David Spencer, Lisa Zarlenga
September 25, 2008
Use of Limited Liability Companies in Corporate Transactions
Mark Silverman, Lisa Zarlenga
July 2008
Partnership Mixing-Bowls
Aaron Nocjar, Mark Silverman
June 2008
Section 382 of the Internal Revenue Code of 1986
Mark Silverman
June 2008
Section 384 of the Internal Revenue Code of 1986
Mark Silverman
June 2008
Tax Treatment of Reorganization Costs
Mark J. Silverman
June 2008
Tax Treatment of Reorganization Costs
Mark Silverman
June 2008
Appendix to S Corporation Rules and the Use of S Corporations as Acquisition Vehicles
Aaron Nocjar, Mark Silverman
May 2008
S Corporation Rules and the Use of S Corporations as Acquisition Vehicles
Aaron Nocjar, Mark Silverman
May 2008
Purchase Price Allocation Rules: Sections 1060, 338, and 197
Mark J. Silverman
2008
Use of Limited Liability Companies in Corporate Transactions
Lisa M. Zarlenga
April 25, 2008
Comparative Anti-Abuse Tax Rules and Policy: Emerging Coherence or a Tower of Babel?
Philip R. West
March 2008, Tax Notes International
How To Make Your Audit Successful Before It Begins … And Handle It After It Starts
Matthew D. Lerner
March 18, 2008
UK Tax Law Update - 2008 UK Budget
Kassim Meghjee
March 2008
Codification of Economic Substance – Is it an Idea Whose Time Has Come…and Gone?
Mark J. Silverman
February 14, 2008
Arizona Tax Update
New Prime Contracting Transaction Privilege Tax Developments
Bennett Evan Cooper, Frank V. Crociata, Pat Derdenger, Randal T. Evans, Dawn R. Gabel, Benjamin F. Gardner
January 2008
Partnership Disguised Sale Rules
Mark Silverman
2008
Purchase Price Allocation Rules: Sections 1060, 338, and 197
Mark Silverman
2008
Section 197 and Partnership Transactions
Mark Silverman
2008
Section 338 and Appendix
Mark Silverman
2008
Section 338(h)(10) and Appendix
Mark Silverman
2008
Section 382--Fluctuation in Value
Mark Silverman
2008
Taxation of Captive Insurers and Related Issues
J. Walker Johnson, Alexis A. MacIvor
January 2008
Taxation of Commercial Banks and Thrift Institutions
J. Walker Johnson, Alexis A. MacIvor
January 2008
Taxation of Financial Asset Securitization Investment Trusts
J. Walker Johnson, Alexis A. MacIvor
January 2008
Taxation of Insurance Products
J. Walker Johnson, Alexis A. MacIvor
January 2008
Taxation of Life Insurance Companies
J. Walker Johnson, Alexis A. MacIvor
January 2008
Taxation of Property and Casualty Insurance Companies
J. Walker Johnson, Alexis A. MacIvor
January 2008
Taxation of Real Estate Investment Trusts
J. Walker Johnson, Alexis A. MacIvor
January 2008
Taxation of Real Estate Mortgage Investment Conduits
J. Walker Johnson, Alexis A. MacIvor
January 2008
Taxation of Regulated Investment Companies
J. Walker Johnson, Alexis A. MacIvor
January 2008
Partnership Mixing Bowl Issues
Mark. J. Silverman, Aaron P. Nocjar
June 2006, Practising Law Institute
S Corporation Rules and the Use of S Corporations as Acquisition Vehicles
Mark J. Silverman, Steven B. Teplinsky, Aaron P. Nocjar
June 2006, Practising Law Institute
S Corporation Rules and the Use of S Corporations as Acquisition Vehicles Appendix
Mark J. Silverman, Aaron P. Nocjar
June 2006, Practising Law Institute
UK Tax Law Update, Issue 2
Kassim Meghjee
November 2007
Alternative Dispute Resolution – An Update
Michael C. Durst
The New York Chapter of Tax Executives Institute
November 7, 2007
Dealing with Tax Documentation and Disclosure Requirements in a FIN 48 and Textron World
Michael C. Durst, Matthew D. Lerner
November 7, 2007
Standards of Tax Practice – An Update
Michael C. Durst
The New York Chapter of Tax Executives Institute
November 7, 2007
Tax Executives Institute Seminar on Mergers and Acquisitions
Gregory N. Kidder, Melanie J. Teplinsky, Lisa M. Zarlenga
October 26, 2007
Acquisition and Separation Issues in Consolidation: Insolvent Corporations and No Net Value Regulations
October 5, 2007
ALI-ABA Course of Study Consolidated Tax Return Regulations - Section 1504 Affiliation Issues
Aaron P. Nocjar, Lisa M. Zarlenga
October 2007
Assessing the Value of the Proposed "No Net Value" Regulations
Mark J. Silverman, Lisa M. Zarlenga, Gregory N. Kidder
October 5, 2007
Comparison of the Intercompany Obligation Rules Under Treas. Reg. 1.1502-13(g) & Prop. Treas. Reg. 1.1502-13(g)
October 5, 2007
Consolidated Return Investment Basis Adjustment Rules: Study Problems
October 5, 2007
Consolidated Return Loss Disallowance and Loss Duplication Rules
Lisa M. Zarlenga
October 5, 2007
Continuity of Interest and Continuity of Business Enterprise Regulations
Mark J. Silverman
October 5, 2007
Current Developments in Tax-Free and Taxable Acquisitions and Separations
Mark J. Silverman
October 5, 2007
Current Developments in Tax-Free Corporate Reorganizations
Mark J. Silverman
October 5, 2007
Fourth Time's a Charm: New Temporary Section 355(e) Regulations Provide Helpful Guidance to Taxpayers
Mark J. Silverman, Lisa M. Zarlenga, Andrew J. Weinstein
October 5, 2007
Intercompany Transaction Problems
October 5, 2007
Legislative Developments: Tax Increase Prevention and Reconciliation
Aaron P. Nocjar
October 5, 2007
Pre-Reorganization Continuity of Interest Regulations
October 5, 2007
Recent Developments in the Step Transaction Doctrine
October 5, 2007
Regulations Governing Intercompany Transactions Within Consolidated Groups
October 5, 2007
Restructuring Troubled Companies
Lisa M. Zarlenga
October 5, 2007
Section 338
October 5, 2007
Section 338(h)(10)
October 5, 2007
Section 338(h)(10) Appendix
October 5, 2007
Section 355(d) Regulations: Narrowing the Scope of an Overly Broad Statute
Mark J. Silverman, Lisa M. Zarlenga, Andrew J. Weinstein
October 5, 2007
Section 382 Consolidated Return Regulations
October 5, 2007
Spin-Offs: The Anti-Morris Trust and Intragroup Spin Provisions
Mark J. Silverman, Lisa M. Zarlenga, Andrew J. Weinstein
October 5, 2007
Who Precedes and Who Succeeds: Proposed Section 355(e)(4)(D) Regulations
Lisa M. Zarlenga, Kevin Spencer
October 5, 2007
Comparison of the Intercompany Obligation Rules Under Treas. Reg. §1.1502-13(g) & Prop. Reg. §1.1502-13(g)
Mark Silverman
October 4, 2007
Payout Requirements for Type I11 Supporting Organizations that Are Not Functionally Integrated
August 1, 2007
UK Tax Law Update, Issue 1
Kassim Meghjee
August 2007
Multinationals and VAT Compliance in the UK
Kassim Meghjee
July 2007, BNAI’s Tax Planning International: Indirect Taxes
A New Form of Obscenity? Sorting through the Federal Circuit’s “We Know It When We See It” Ruling in Coltec
Gregory N. Kidder
June 13, 2007
No Net Value Regulations (article)
Lisa Zarlenga, Gregory Kidder
June 2007
Section 382 Fluctuation in Value
June 2007
Section 382 of the Internal Revenue Code of 1986
June 2007
Section 384 of the Internal Revenue Code of 1986
June 2007
Tax Planning for Contributions of Property to Partnerships; Partnership Disguised Sale Rules
The Final Regulations Under Section 707(a)(2)
Mark J. Silverman, Aaron P. Nocjar
June 2007
6001, 6662, 404, 48 – Hut! Circling the Wagons and Protecting Your Tax Documentation
Matthew D. Lerner
May 16, 2007
New Section 199 Domestic Production Deduction and How it Applies to the Construction and Real Estate Development Industry
Frank V. Crociata, Pat Derdenger
2007, The Real Estate Finance Journal - A Thompson/West Publication
Daily Tax Update - April 9, 2007
Section 470 and Partnerships Left Outside Future Congressional Relief
Aaron P. Nocjar
April 2, 2007, Tax Management Memorandum, a BNA Company
Don't Make Coltec Problem Worse
Gregory N. Kidder
March 26, 2007, Vol XXX No 13 Legal Times
UK Budget
Kassim Meghjee
March 21, 2007
Coltec and Its Consequences
Matthew D. Lerner
American Bar Association Section of Taxation Midyear Meeting
January 20, 2007
Economic Substance Doctrine: Sorting Through the Federal Circuit's "We Know It When We See It" Ruling in Coltec
Mark J. Silverman, Matthew D. Lerner, and Gregory N. Kidder
December 31, 2006, The Tax Executive (November-December 2006)
The New Pension Protection Act: More Work for Plan Administrators
Anne E. Moran and Karen Tucker
Winter 2006, Employee Relations Law Journal Vol 32 No 3
A New Form of Obscenity? Sorting through the Federal Circuit’s “We Know It When We See It” Ruling in Coltec
Matthew Lerner, Mark Silverman, Gregory Kidder
November 1, 2006
Coltec and Its Consequences
Mark J. Silverman and Arthur L. Bailey
October 26, 2006
Acquisition and Separation Issues in Consolidation: Insolvent Corporations and No Net Value Regulation (10/5/2006)
Corporate Divisons Under Section 355
October 5, 2006
Current Developments in Tax-Free and Taxable Acquisitions and Separations
Mark Silverman
October 5, 2006
Spend Now, Spend Later: New Protections for Retirement Account Assets in Bankruptcy
Anne E. Moran
Summer 2006, Employee Relations Law Journal
Taxation of Financial Institutions and Products
J. Walker Johnson
July 2006
EU Financial Services Briefing
Guy Soussan, Philip Woolfson
June 2006
Section 338 Appendix
June 2006
Section 197 and Partnership Transactions
Mark J. Silverman, Aaron P. Nocjar
June 2006, Practising Law Institute
Arizona Tax Update 2003-2005
Pat Derdenger
May 2006
Income Tax Nexus and Public Law 86-272 for Tax Executives Institute
Pat Derdenger
April 19, 2006
Surprises in Severance Packages: New Deferred Compensation Rules Limit Flexible Arrangements
Anne E. Moran
Spring 2006, Employee Relations Law Journal
EU Financial Services Briefing
Philip Woolfson
February 2006
Circular 230: Is the Hysteria Over?
Arthur L. Bailey, Alexis A. Maclvor
January 2006
EU Financial Services Briefing
Philip Woolfson
December 2005
Final Section 355(e) Plan Regulations: The Final Chapter in the Saga
Lisa M. Zarlenga
November 1, 2005
Obtaining and Providing Outside International (and Other) Tax Advice in the Current Tax Enforcement and Compliance Environment
Philip R. West
October 1, 2005
So You've Become a Fiduciary: Signposts, Suggestions, and Sympathy
Anne E. Moran
Fall 2005, Employee Relations Law Journal
Consolidated Return Investment Basis Adjustment Rules
Mark Silverman
September 23, 2005
Consolidated Return Investment Basis Adjustment Rules Study Problems
Mark Silverman
September 22, 2005
Section 355(d) Regulations
Narrowing the Scope of an Overly Broad Statute
Mark J. Silverman, Lisa M. Zarlanga, Andrew J. Weinstein
September 22, 2005
Current Developments in Tax Shelters
Matthew D. Lerner
September 2005
Limitation on Loss Duplication and Importation of Built-in Losses
September 1, 2005
Deferred Compensation Legislation Casts a Wide Net
All Employers Need to Review Their Severance, Employment, and Compensation Arrangements
Anne E. Moran
Summer 2005, Employee Relations Law Journal
Proposed Regulations Would Permit Cross-Border "A" Reorganizations for the First Time in 70 Years
Lisa M. Zarlenga
July 1, 2005
Proposed Regulations Would Permit Cross-Border "A" Reorganizations for the First Time in 70 years
Mark Silverman, Lisa Zarlenga
July 2005
Tax Treatment of Reorganization Costs
Mark J. Silverman, Andrew Weinstein
July 1, 2005
An Analysis of the Proposed US Regs on Cross-Border Mergers
Lisa M. Zarlenga
June 6, 2005
News Analysis: Pasquantio Case Raises International Planning Concerns
Philip R. West, Keith A. Sieverding
May 30, 2005
How to Make Your Audit Successful Before It Begins and Handle It After It Starts
J. Walker Johnson, Matthew Lerner, Pat O'Malley
April 26, 2005
Stopping Pension Leaks: New Rules Requiring Default IRA Rollovers Go Into Effect in 2005
Anne E. Moran
Spring 2005, Employee Relations Law Journal
Tax Procedure Outline: Audit to Litigation
J. Walker Johnson
March 15, 2005
Re-Thinking Check-the-Box: Subpart F
Philip R. West
March 1, 2005
New Circular 230 Regulations Impose Strict Standards for Tax Practitioners
Arthur L. Bailey, Alexis A. MacIvor
February 2005
Current Developments in Corporate Tax
January 24, 2005
The Roth 401(k): Glitter or Gold?
Anne E. Moran
Winter 2005, Employee Relations Law Journal
Tax Procedure Outline: Audit to Litigation
J. Walker Johnson
December 16, 2004
McDowell Clarifies Nonprofits’ Tax, Net Issues
November 9, 2004
Impact of American Jobs Creation Act, Long Term Capital Holdings, Black & Decker, Coltec, TIFD III-E and Other Tax Shelter Developments
Matthew D. Lerner, Philip R. West
November 2004
IRS Audits of Executive Compensation: Need to Review
Anne E. Moran
Summer 2004, Employee Relations Law Journal
Should Nonprofits Adopt the Provisions of Sarbanes-Oxley?, Taxation of Exempts, July 2004
Suzanne Ross McDowell
HSAs: The New Consumer Health Plan
Is This the Real Thing?
Anne E. Moran
Summer 2004, Employee Relations Law Journal
Letter Ruling Alert: Hospital Obtains Ruling that Process for Setting Interest Rates Meets Requirements of Section 4958
Suzanne Ross McDowell
June 2004, 44 The Exempt Organization Tax Review 191
Establishing Business Purpose in a Transparent World
Philip R. West
May 14, 2004
Exploiting IP
April 29, 2004
Taxation of Property and Casualty Insurance Companies
J. Walker Johnson
January 16, 2004
Foreign Law in US International Taxation: The Search for Standards
Philip R. West
July 1, 1996
Florida Tax Review
Application of Taxation Rate Reductions in JGTRRA to Closely Held Foreign Corporations
Philip R. West
January 2, 2004
Contingent Workforce: Challenge for Benefits Managers
Anne E. Moran
Winter 2004, Employee Relations Law Journal
Acquisition and Separation Issues in Consolidation: Insolvent Corporations
Mark Silverman
October 2, 2003
Delinquent 401(k) Deposits: Labor Dept's Tough Enforcement
Anne E. Moran
Summer 2003, Employee Relations Law Journal
New Temporary Section 355(e) Regulations
A Vast Improvement
Lisa M. Zarlenga
August 1, 2003
Applying the Unrelated Debt-Financed Income Rules to Investments in Real Property
Suzanne Ross McDowell
July 2003, 15 Taxation of Exempts 3
RITE AID: A Tough Pill for the Government to Swallow
Lisa M. Zarlenga
June 2003
Managing Intellectual Property: Tax and Nontax Aspects
April 25, 2003
New IRS Minimum Distribution Regulations: Roadmap for the Weary
Anne E. Moran
Spring 2003
VEBAS: Possibilites For Employee Benefit Funding
Anne E. Moran
Winter 2003
What You Need to Know About the Unrelated Debt-Financed Income Rules
Suzanne Ross McDowell
March 2003, 14 Taxation of Exempts 206
Letter Ruling Alert: CRUT Avoids UBTI by Investing Through a Foreign Corporation
Suzanne Ross McDowell and Randal T. Evans
February 2003, 39 The Exempt Organization Tax Review 204
International Joint Ventures
Selected Practical Considerations
Philip R. West
Winter 2003, Taxation of Global Transactions
2002: A Year in Review for International Tax Practitioners
Philip R. West
November 21, 2002
Tax Shelter Developments
Philip R. West
November 21, 2002
Comparative Taxation
Some Basic Points
Philip R. West
November 8, 2002
Limitation on Benefits Provisions in Tax Treaties
Philip R. West
October 17, 2002
Stock Option Fundamentals
Anne E. Moran
Fall 2002, Employee Relations Law Journal
Protections for Employees Called into Military Service
Anne E. Moran
September 5, 2002
On Second Thought: Modifying Retiree Health Plans
Anne E. Moran
September 3, 2002
The Challenge of Providing Health Benefits for Domestic Partners
Anne E. Moran
September 2, 2002
The Proposed Section 355(e) Regulations
Broadening the Traditional Notions of What Constitutes a Plan
Lisa M. Zarlenga
August 28, 2002
Corporate Sponsorship Payments Final Regulations Concerning Taxation of Tax-Exempt Organizations
Catherine W. Wilkinson
July 5, 2002
Loss Disallowance Rules
July 1, 2002
IRS Issues New Tax Regulations on Domestic Reverse Hybrid Entities
Stanley Smilack, Philip R. West
June 11, 2002
New Tax Proposals Aimed at Foreign-Owned Businesses
Stanley Smilack, Philip R. West
June 6, 2002
Problem Set and Glossary of Terms for the Section 382/SRLY Consolidated Return Regulations
September 18, 2001
The Treatment of Contingent Liablities in Taxable Asset Acquisitions
Ryan B. Hotchkiss
August 25, 2001
Current Developments in Tax-Free Acquisitions and Separations
August 1, 2001
TEI Education Funds
August 1, 2001
The Regulations Governing Intercompany Transactions Within Consolidated Groups
Lisa M. Zarlenga
August 1, 2001
Attributing profits to a PE
A US perspective
Philip R. West
July 30, 2001
Highlights of The New US - UK Tax Treaty
July 30, 2001
Twentieth Annual J. Nelson Young Tax Institute Considerations in Mergers & Acquisitions
April 1, 2001
Current Developments in Tax-Free Corporate Reorganizations Appendix
January 6, 2001
Section 382 of the Internal Revenue Code of 1986 Appendix
January 6, 2001
Rite Aid: A Tough Pill for the Government to Swallow
Lisa M. Zarlenga
2001
The Proposed Section 355(e) Regulations
Broadening the Traditional Notions of What Constitutes a Plan
Lisa M. Zarlenga
August 6, 2000
Lecture on Incorporations, Liquidations and Distributions
June 1, 2000
Final Regulations Concerning Public Disclosure of Materials Relating to Tax-Exempt Organizations
Catherine W. Wilkinson, Catherine J. Martin, Gordon M. Clay
May 18, 1999
Revenue Ruling 98-27 and New Spin-off Control Provision in IRS Restructuring Bill
May 28, 1998
Tax Alert - H.R. 1365 and S. 612 - Elimination of Morris Trust Transactions
April 21, 1997
ACM Partnership v. Commissioner, Sham Transaction - No Economic Substance
March 24, 1997
IRS Reverses Itself and Allows Deduction of Environmental Clean-Up Related Costs
January 1, 1996
Acquisition and Separation Issues in Consolidation: Insolvent Corporations

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