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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ODLs and Switching from Deducting to Crediting Foreign Taxes, By Dirk J.J. Suringa,
Esq....November 2009 |
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Notice 2009-78: The IRS Amends §7874 by Notice, By Philip D. Morrison,
Esq....November 2009 |
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More International Tax Enforcement: Leading with the Foreign
Account Tax Compliance Act of 2009, By Edward Tanenbaum,
Esq....November 2009 |
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Schering-Plough Corp. v. United States: Subpart F Analysis Gone
Awry, By Lowell D. Yoder,
Esq....November 2009 |
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ERISA Section 510: The Setting Is Ripe for Claims, By John S. Zollo,
Esq....November 2009 |
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Required Minimum Distributions in 2009: What the IRS Forgot to
Mention, By Jeffrey C. Chang, Esq. and Kenneth W. Ruthenberg,
Esq....November 2009 |
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IRS Publishes Benefit Plan Audit Materials, By James G. Isaac, Susan Peters Schaefer & Karen A.
Simonsen...November 2009 |
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EEOC Cracks Down on Leave Policies that May Violate the ADA, By Michael J. Canavan, Esq....November 2009 |
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On Various Proposals to Strengthen and Extend the QI Regime --
Part One: Redefining the QI's Role, By Kimberly S. Blanchard, Esq....October 2009 |
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After Textron: “What Is to Be Done?”, By Kenneth J. Krupsky, Esq....October 2009 |
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Tricky Derivatives, By James J. Tobin, Esq....October 2009 |
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Adjustments of Rights Within Cost-Sharing Arrangements, By Gary D. Sprague...October 2009 |
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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 |
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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 |
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IRS Provides Guidance on the Taxation of Employment-Related
Settlement Payments, By Elizabeth Erickson & Ira B.
Mirsky...October 2009 |
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IRS to Audit 6,000 Companies in National Research Program
Initiative to Test Employment Tax Compliance, By Ira B. Mirsky...October 2009 |
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FICA Status of Full-Time Medical Residents Resolved?, By Peter J. Allman, Esq....October 2009 |
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After Textron: New Legislation “Carries” Heavy Burden for Private Equity Fund Managers, By Lisa Marie Starczewski, Esq. and Andrew W.
Needham....October 2009 |
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Compensation of Executives of Charitable Organizations, By Carla Neeley Freitag....October 2009 |
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Bill Introduced to Repeal the Federal Defense of Marriage Act, By Jonathan J. Boyles, Todd A. Solomon & Brian J. Tiemann....October 2009 |
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Medical Expenses Should be Deductible by All - Then Tax Issues
Won’t Cause Reform to Fall, By Gerald S. Deutsch, Esq....October 2009 |
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Ninth Circuit Defines Window for Suing Under §7431, By Theodore D. Peyser, Esq....September 2009 |
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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 |
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Taxpayer Victory in Partnership Case, By Steven B. Gorin, Esq....September 2009 |
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IRS Examiners Directed to Review Estate and Gift Tax Returns for
Preparer Penalties, By Marianne R. Kayan, Esq....September 2009 |
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Check-the-Box Overruled for Gift Tax Purposes for Single Member
LLC, By Steven B. Gorin, Esq....September 2009 |
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A Joint Return? But You’re Getting Divorced -- Yet a Proper
Agreement Can Reduce Your Cost, By Gerald S. Deutsch, Esq....September 2009 |
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Settlement Proceeds from Class Action Breach of Contract Suit
Excludible under §104(a)(3), By Theodore D. Peyser, Esq....September 2009 |
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Overriding Income Tax Treaties in Codifying a New LOB,
By Philip D. Morrison, Esq....September 2009 |
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Building Tax Walls in the 21st Century,
By James J. Tobin, Esq....September 2009 |
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Subpart F: “Indicia of Manufacturing”,
By Lowell D. Yoder, Esq....September 2009 |
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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 |
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FBAR the Door,
By Dirk J.J. Suringa, Esq....August 2009 |
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Exchangeable Shares Guidance in the Form of §7874 Temporary
Regulations?,
By Kimberly S. Blanchard,
Esq....August 2009 |
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China's New Tax Incentive for “High and New Technology
Enterprises”,
By Kenneth J. Krupsky,
Esq....August 2009 |
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Corporate Inversions - Round Four: The New -2T Regulations,
By Edward Tanenbaum,
Esq....August 2009 |
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State Taxation and Personal Goodwill,
By Richard Reichler,
Esq....August 2009 |
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Navigating Qualified Plan Correction in Light of IRS and DOL
Differing Perspectives,
By Marcia S. Wagner, Esq. and Diane Goulder Cohen,
Esq....August 2009 |
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Treasury Issues New Executive Compensation Rules for TARP
Recipients; Proposes Guidelines for Future Legislation,
By Michael G. Kushner, Esq....July 2009 |
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The Obama Check-the-Box Proposal--Notice 98-11 Redux,
By Philip D. Morrison, Esq....July 2009 |
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Voluntary Payments, Italian Style,
By Dirk J.J. Suringa, Esq....July 2009 |
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Obama Administration's Proposal to Limit Classification of Foreign
Entities as Disregarded Is Misguided,
By Lowell D. Yoder, Esq....July 2009 |
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Xilinx: A Case Study in Judicial Activism,
By Charles Cope and Thomas
Zollo....July 2009 |
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New FASB Accounting Standards Codification Changes GAAP Research
and References (E.g., FAS 109 and FIN 48),
By Laura C. Kinney, Esq....July 2009 |
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Ability of Bankruptcy Trustee to Reach Post-petition Distributions
from Trusts,
By Richard W. Nenno, Esq....July 2009 |
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Clarification Continues on Foreign Bank Account Reporting,
By Marianne R. Kayan, Esq....July 2009 |
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IRS Notice Clarifies Tax Treatment of Employer-owned Life
Insurance,
By Michael G. Kushner, Esq....July 2009 |
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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 |