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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
> ODLs and Switching from Deducting to Crediting Foreign Taxes, By Dirk J.J. Suringa, Esq....November 2009
> Notice 2009-78: The IRS Amends §7874 by Notice, By Philip D. Morrison, Esq....November 2009
> More International Tax Enforcement: Leading with the Foreign Account Tax Compliance Act of 2009, By Edward Tanenbaum, Esq....November 2009
> Schering-Plough Corp. v. United States: Subpart F Analysis Gone Awry, By Lowell D. Yoder, Esq....November 2009
> ERISA Section 510: The Setting Is Ripe for Claims, By John S. Zollo, Esq....November 2009
> Required Minimum Distributions in 2009: What the IRS Forgot to Mention, By Jeffrey C. Chang, Esq. and Kenneth W. Ruthenberg, Esq....November 2009
> IRS Publishes Benefit Plan Audit Materials, By James G. Isaac, Susan Peters Schaefer & Karen A. Simonsen...November 2009
> EEOC Cracks Down on Leave Policies that May Violate the ADA, By Michael J. Canavan, Esq....November 2009
> On Various Proposals to Strengthen and Extend the QI Regime -- Part One: Redefining the QI's Role, By Kimberly S. Blanchard, Esq....October 2009
> After Textron: “What Is to Be Done?”, By Kenneth J. Krupsky, Esq....October 2009
> Tricky Derivatives, By James J. Tobin, Esq....October 2009
> Adjustments of Rights Within Cost-Sharing Arrangements, By Gary D. Sprague...October 2009
> The “Big Three” VEBAs and other Stand-Alone Welfare Benefit Trusts: What Is and Is Not Novel About Them, By Andrew W. Stumpff...October 2009
> Deductible Miscellaneous Expenses Must Always Be in Excess of 2%, But No Amount Is Deductible for the AMT, By Gerald S. Deutsch, Esq....October 2009
> IRS Provides Guidance on the Taxation of Employment-Related Settlement Payments, By Elizabeth Erickson & Ira B. Mirsky...October 2009
> IRS to Audit 6,000 Companies in National Research Program Initiative to Test Employment Tax Compliance, By Ira B. Mirsky...October 2009
> FICA Status of Full-Time Medical Residents Resolved?, By Peter J. Allman, Esq....October 2009
> After Textron: New Legislation “Carries” Heavy Burden for Private Equity Fund Managers, By Lisa Marie Starczewski, Esq. and Andrew W. Needham....October 2009
> Compensation of Executives of Charitable Organizations, By Carla Neeley Freitag....October 2009
> Bill Introduced to Repeal the Federal Defense of Marriage Act, By Jonathan J. Boyles, Todd A. Solomon & Brian J. Tiemann....October 2009
> Medical Expenses Should be Deductible by All - Then Tax Issues Won’t Cause Reform to Fall, By Gerald S. Deutsch, Esq....October 2009
> Ninth Circuit Defines Window for Suing Under §7431, By Theodore D. Peyser, Esq....September 2009
> Courts of Appeals Hold §6501(e)(1)(A) Is Not Triggered in the Case of an Understatement of Gain Due to Omission, By Theodore D. Peyser, Esq....September 2009
> Taxpayer Victory in Partnership Case, By Steven B. Gorin, Esq....September 2009
> IRS Examiners Directed to Review Estate and Gift Tax Returns for Preparer Penalties, By Marianne R. Kayan, Esq....September 2009
> Check-the-Box Overruled for Gift Tax Purposes for Single Member LLC, By Steven B. Gorin, Esq....September 2009
> A Joint Return? But You’re Getting Divorced -- Yet a Proper Agreement Can Reduce Your Cost, By Gerald S. Deutsch, Esq....September 2009
> Settlement Proceeds from Class Action Breach of Contract Suit Excludible under §104(a)(3), By Theodore D. Peyser, Esq....September 2009
> Overriding Income Tax Treaties in Codifying a New LOB, By Philip D. Morrison, Esq....September 2009
> Building Tax Walls in the 21st Century, By James J. Tobin, Esq....September 2009
> Subpart F: “Indicia of Manufacturing”, By Lowell D. Yoder, Esq....September 2009
> Advantages to a Foreign Parent Corporation of Setting Up a U.S. R&D Facility as a Branch Rather Than a U.S. Corporation, By Herman B. Bouma, Esq....September 2009
> FBAR the Door, By Dirk J.J. Suringa, Esq....August 2009
> Exchangeable Shares Guidance in the Form of §7874 Temporary Regulations?, By Kimberly S. Blanchard, Esq....August 2009
> China's New Tax Incentive for “High and New Technology Enterprises”, By Kenneth J. Krupsky, Esq....August 2009
> Corporate Inversions - Round Four: The New -2T Regulations, By Edward Tanenbaum, Esq....August 2009
> State Taxation and Personal Goodwill, By Richard Reichler, Esq....August 2009
> Navigating Qualified Plan Correction in Light of IRS and DOL Differing Perspectives, By Marcia S. Wagner, Esq. and Diane Goulder Cohen, Esq....August 2009
> Treasury Issues New Executive Compensation Rules for TARP Recipients; Proposes Guidelines for Future Legislation, By Michael G. Kushner, Esq....July 2009
> The Obama Check-the-Box Proposal--Notice 98-11 Redux, By Philip D. Morrison, Esq....July 2009
> Voluntary Payments, Italian Style, By Dirk J.J. Suringa, Esq....July 2009
> Obama Administration's Proposal to Limit Classification of Foreign Entities as Disregarded Is Misguided, By Lowell D. Yoder, Esq....July 2009
> Xilinx: A Case Study in Judicial Activism, By Charles Cope and Thomas Zollo....July 2009
> New FASB Accounting Standards Codification Changes GAAP Research and References (E.g., FAS 109 and FIN 48), By Laura C. Kinney, Esq....July 2009
> Ability of Bankruptcy Trustee to Reach Post-petition Distributions from Trusts, By Richard W. Nenno, Esq....July 2009
> Clarification Continues on Foreign Bank Account Reporting, By Marianne R. Kayan, Esq....July 2009
> IRS Notice Clarifies Tax Treatment of Employer-owned Life Insurance, By Michael G. Kushner, Esq....July 2009
> In These Tough Times With So Much Pain - It’s More Important Than Ever to Get Capital Gain, By Gerald S. Deutsch, Esq....July 2009