ARTICLES AND PRESENTATIONS
Further Guidance Needed on Who Must Report Foreign Accounts, Tax Notes (May 25, 2009) 1023 (view article)
Brief Outline of U.S. Tax Considerations Relevant to Artists, Entertainers and Athletes with a Particular Emphasis on Their Personal Appearance Income (IBA, London, March 6-7, 2006)
The Attempted Extra Statutory Application Of “Withholding” Under Sections 1441 And 1446 In Respect Of Income Of Certain U.S. Persons, The Mysterious Nature Of The Section 1446 Withholding Tax Liability And Certifiable Hysteria Precluding Reliance On Payee’s Certificates And Other Anamolies (June 13, 2005)
The Complex Domestic Trust, a Potential Vehicle for Reducing the Tax on U.S. Source Non-Effectively Connected Dividend Income of Non-U.S. Persons and Capital Gains of Certain Corporations? (September, 2003)
Treaty Entitlements through the Looking Glass: Changing the Meanings but Not the Words, Tax Review (April, 2001)
Tax Planning and Pitfalls for International Entertainers Case Study: U.S. Perspective, Section I -- Source Country -- Non Treaty Situation, and Outline of Comments to the General Structure of the Contract, IBA, Barcelona (September, 1999)
Article 17 – the Artiste Clause – Time for Reconsideration, Tax Club (January, 1999)
Proposed Expatriation Rules (April, 1995)
Entitlement to Treaty Benefits: a Comparison of the Dutch and German Solutions (September, 1994)
Certain Tax Consideration relating to Acquisitions of U.S. Investments by Non-U.S. Persons, N.Y. University, 52nd Institute of Federal Taxation (November, 1993)
Certain Tax Issues Relating to International Commercial Agreements, PLI (October, 1993)
Limitation on Benefits, an Overview, Tax Review (December, 1990)
Whither the Branches, 44 Tax Law Review No.2, 205 (1989) (co-authored with Mark E. Berg)
An Analysis of the Temporary Regulations Under FIRPTA, Part II, 69 J. Taxation, No. 5, 348 (1988) (co-authored with Peter A. Glicklich)
An Analysis of the Temporary Regulations Under FIRPTA, Part I, 69 J. Taxation, No. 4, 262 (1988) (co-authored with Peter A. Glicklich)
Source and Certain Other Jurisdictional Limitations in Light of the Tax Reform Act of 1986, Tax Review (May, 1987)
New Regime of Branch Level Taxation Now Imposed on Certain Foreign Corporations, 66 J. Taxation, No. 1, 2 (1987)
Source of Income From Sales of Personal Property, 35 Can. Tax Journal, 473 (March-April, 1987) (co-authored with Marlene F. Schwartz)
New Statutory Definition of Resident Alien under the Tax Reform Act of 1986, 44 NYU Inst. on Fed. Tax, 46 (1986)
Broad FIRPTA Withholding Rules are Bound to Affect Canadians, 33 Can. Tax Journal, No. 1, 170-88 (1985) (co-authored with Peter A. Glicklich)
Has the 30 Per Cent. Tax on Portfolio Interest Been Eliminated? The British Tax Review, 1985 No. 4 (co-authored with Richard G. Fishman)
Revenue Rulings 84-152 and 84-153: Treaty Shopping- Let the Buyer Beware, 33 Can. Tax Journal, No. 1, 158 (January-February, 1985) (Co-authored with Kenneth R. Silbergleit)
Broad FIRPTA Withholding Rules are Bound to Affect Canadians, 33 Can. Tax Journal, No. 1, 170 (January-February, 1985) (co-authored with Peter A. Glicklich)
DRA's Elimination of Withholding Tax on Portfolio Interest, 65 J. Taxation No. 3, 170 (1985) (co-authored with Richard G. Fishman)
Onerous FIRPTA Reporting Requirements Replaced by New Broad Withholding Rules, 61 J. Taxation No. 5, 298 (November, 1984) (co-authored with Peter A. Glicklich)
U.S. Taxation of OID Income to Foreign Persons After the 1984 Tax Reform Act, Tax Notes, (September 10, 1984) (co-authored with Frank M. Cappuccio)
An Analysis of the New Law Tests for an Alien's Status as a U.S. Resident, 61 J. Taxation, No. 4, 228 (1984)
FIRPTA – An Overview of the New Proposed Regulations, 32 Can. Tax Journal, No. 1, 147 (January-February, 1984)
Proposal Before Congress to Define U.S. Resident Status, 31 Can. Tax Journal No. 5, 853 September-October, 1984) (co-authored with Herbert H. Alpert with assistance from J. Ross McDonald)
Recent Procedural Changes Relating to Restructuring Holdings in Foreign Corporations May Have Substantive Significance, 31 Can. J. Taxation, No. 3, 469 (May-June 1983) (co-authored with Richard G. Fishman)
The Viability of the Personal Service Corporation- the Tax Court is Once Again Heard From, 30 Can. Tax Journal, No. 1, 107-12 (1982)
Observations on the Foreign Investment in Real Property Tax Act of 1980, 1 Va. Law Review, No. 1, 105 (1981) (co-authored with Herbert H. Alpert)
The Source of a Guarantor's Income, 29 Can. Tax Journal, No. 6, 233-37 (1981)
The Use of Substantial Equipment or Machinery at Any Time During the Year as a Permanent Establishment, 28 Can. Tax Journal, No. 2, 222 (1980)
Tax Reform Act Toughens Foreign Transfer Provisions of 1491, and liberalizes 367, 46 J. Taxation 2 (1977) (co-authored with Herbert H. Alpert)
Judicial Deference to Tax Regulations: A Reconsideration in Light of National Cable, Swallows Holding and Other Developments, 61 Tax Lawyer 481 (2008) (view article)
Attorney Suggests Changes to Proposed Regs on Practice Standards, Return Preparer Penalties, 2007 Tax Notes Today 213-19 (November 2, 2007)
Selected Issues Regarding S Corporations With Foreign Operations, outline and panel discussion (moderator) before the American Bar Association Section of Taxation’s S Corporations Committee, Vancouver, British Columbia (September 28, 2007)
Practitioners’ Reaction Indicates Need for Clearer Circular 230 Rules, 108 Tax Notes 245 (July 11, 2005)
The Treatment of Partnerships, LLCs and S Corporations Under Income Tax Treaties, Business Entities, July/August 1999, at 20
Tax Court Refuses to Attribute a Shareholder's Intangible Assets to the Corporation, 10 Journal of S Corporation Taxation 146 (1998)
Recent Pass-Through Entity Developments, 9 Journal of S Corporation Taxation 370 (1998)
Source of Gain or Loss on Sales of S Corporation Stock, 9 Journal of S Corporation Taxation 179 (1997)
Payments to Non-U.S. Pass-Through Entities, Treaty Benefits and the New Proposed Withholding Regulations, 8 Journal of S Corporation Taxation 369 (1997)
Checking the Box: New Proposed Regulations Would Simplify Entity Classification and Afford Planning Opportunities, 8 Journal of S Corporation Taxation 195 (1997)
Brown Group Redux: The Eighth Circuit Speaks, 8 Journal of S Corporation Taxation 161 (1996)
Equity Investments by Pension Funds: The ERISA Plan Assets Rule, 8 Journal of S Corporation Taxation 69 (1996)
Corporate Distributions of Partnership Interests: The Pope & Talbot Case, 7 Journal of S Corporation Taxation 330 (1996)
Final Anti-Abuse Regulations Address the Aggregate/Entity Issue, 7 Journal of S Corporation Taxation 168 (1995)
How Tax Treaties Affect Use of LLCs in International Transactions, 2 Journal of Limited Liability Companies 20 (1995)
Brown Group Revisited, 7 Journal of S Corporation Taxation 71 (1995)
Recasting Havoc: The Impact of the Proposed Partnership Anti-Abuse Rules on S Corporations as Partners, 6 Journal of S Corporation Taxation 317 (1995)
The Continuing Aggregate/Entity Saga: Brown Group is Right, 6 Journal of S Corporation Taxation 271 (1995)
Aggregate/Entity Concepts for S Corporations: Recent Decisions a Mixed Bag, 6 Journal of S Corporation Taxation 185 (1994)
Impact of the New U.S.-Netherlands Treaty on REIT Investments, 6 Journal of S Corporation Taxation 80 (1994)
The RRA '93 Relief for Workouts of Troubled Real Property Debt: Impact on S Corporations and Partnerships, 5 Journal of S Corporation Taxation 349 (1994)
International Investments Through S Corporations, outline and presentation to National Institute of Tax Professionals, New York, New York (November 3, 1993)
Multistate Planning With S Corporations, outline and panel discussion before the American Bar Association Section of Taxation’s S Corporations Committee, New York, New York (August 6, 1993)
The Application of the Built-in Gains Tax to S Corporations as Partners, 5 Journal of S Corporation Taxation 174 (1993)
Planning for S Corporations With New York Operations or Shareholders: Part II, 5 Journal of S Corporation Taxation 93 (1993)
Planning for S Corporations With New York Operations or Shareholders: Part I, 4 Journal of S Corporation Taxation 379 (1993)
Federal Income Tax Treatment of Intangibles, outline and presentation to New Jersey State Bar Association Tax Section, Newark, New Jersey (March 17, 1993)
Cooperatives and their Patrons: The Status of Interest on Working Capital, 4 Journal of S Corporation Taxation 169 (1992)
Passive Income Problems of an "S" Corporation, New York Law Journal, August 13, 1992, at 5
Limitations on Partner-Level Deductions Affect Partnership Withholding, 4 Journal of S Corporation Taxation 100 (1992)
Resolving the Class Struggle: New Proposed One-Class-of-Stock Regulations, 3 Journal of S Corporation Taxation 267 (1992)
The Impact on S Corporations and Their Shareholders of New York and Other Local Tax Laws, outline and New York State Bar Association continuing legal education presentation, New York, New York (April 30, 1992)
Both a Borrower and a Lender Be: The New "Self-Charged" Interest Rules, 3 Journal of S Corporation Taxation 194 (1992)
New York Tax Rules May Reduce Corporate Loss Carryovers, New York Law Journal, Dec. 12, 1991, at 5 (co-authored with Joseph Lipari)
The 'Kinder and Gentler' Proposed Single-Class-of-Stock Regulations, 53 Tax Notes 713 (Nov. 11, 1991) (co-authored with Jerald D. August, Richard D. Blau and Bruce N. Lemons)
New Proposed Tax Rules on 'S Corporation' Eligibility, New York Law Journal, Oct. 3, 1991, at 5
Venturing Beyond the Straight-Debt Safe Harbor: Treasury Founders on the Legislative History, Journal of Taxation of S Corporations, Summer 1991, at 10
The Passive Activity Loss Limitation: Special Considerations for S Corporation Shareholders, outline and panel discussion before the American Bar Association Section of Taxation’s S Corporations Committee, Washington, DC (May 17, 1991)
Using Split-Dollar Life Insurance Arrangements for Employees and Shareholders, 2 Journal of S Corporation Taxation 171 (1991) (co-authored with William C. Schanlaber)
Use of S Corporations in Split-Dollar Insurance Arrangements and Advanced Estate Planning Techniques, outline and panel discussion before the American Bar Association Section of Taxation’s S Corporations Committee, Washington, DC (May 4, 1990)
Whither the Branches?, 44 Tax Law Review 205 (1989) (branch profits tax) (co-authored with Fred Feingold)
Treaty Provisions Found Not to Prohibit Excess Interest Tax, 37 Canadian Tax Journal 1092 (1989)
Losses and the Partner: Toward a Rational Basis Standard, 3 Journal of Partnership Taxation 195 (1986) (co-authored with Kenneth H. Heitner)
New Standard for Tax Return Preparers is Inappropriate, 116 Tax Notes 559 (August 13, 2007)
Taxation of Unvested Profits Interests; Revenue Procedure 2001-43, 92 Tax Notes 1114 (August 20, 2001)
Corporate Finance: Business Acquisitions and Leveraged Buyouts (1997) (co-author)
Accounting and Tax Planning for Joint Ventures and Partial Business Combination (1995) (co-author)
Tax Planning for Mergers and Acquisitions in the Mergers and Acquisition Handbook (2d ed., 1993) (co-author)
Mismatched Effective Rates Provisions in Proposed Consolidated Return Regulations can Create Unexpected Tax Consequences, 58 Tax Notes 1375 (March 8, 1993)
Proposal Before Congress to Define U.S. Resident Status, Canadian Tax Journal, Selected U.S. Tax Developments, Volume 31, Number 5, (September-October 1983) (co-authored with Fred Feingold with assistance from J. Ross McDonald)
The Coordination Between the New Canada-U.S. Treaty and the U.S. Foreign Investment in Real Property Tax Act, Canadian Tax Journal, Selected U.S. Tax Developments, (July-August 1981)
Observations on the Foreign Investment in Real Property Tax Act of 1980, Virginia Tax Review, Volume 1, Number 1, (Spring 1981) (co-authored with Fred Feingold)
U.S.A.: Foreign Investment in Real Property Tax Act 1980, Bulletin for International Fiscal Documentation, Vol. 35, 1981, No. 5 (May 1981) (co-authored with Fred Feingold)
Intra-Group Utilization of Losses in the United States – The Consolidated Return, Canadian Tax Foundation (November 1979)
'76 Act Provisions Affecting Nonresident Aliens, The Tax Adviser (May 1977) (co-authored with Fred Feingold)
Tax Report Act Toughens Foreign Transfer Provisions of 1491 and Liberalizes 367, Journal of Taxation (January 1977) (co-authored with Fred Feingold)
Doing Business in Puerto Rico through a Possessions Corporation, The Tax Lawyer, Spring, 1974 (panel discussion) (co-authored with Cunningham and Van Kirk)
Reverse Acquisition Problems, NYU 31st Annual Institute on Federal Taxation (1973) (with Schwartz)
New Regulations Provide Workable Rules for Real Estate Limited Partnerships, 14 J. Taxation 230 (1961) (with Sidney I. Roberts)
Congress Approves Real Estate Investment Trust; Exacting Rules Made, 13 J. Taxation 194 (1960) (with Sidney I. Roberts and Feder)
Subchapter S: Semantic and Procedural Traps in its Use; Analysis of Dangers, 10 J. Taxation 2 (1959)