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Sham Stock Sales: Acqis Technology v. Commissioner
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 04/18/2024
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Federal Tax Guidance Overturned Under Administrative Procedure Act
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 04/21/2022
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Transaction 'Integration': 'GSS Holdings (Liberty) v. United States'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 08/19/2021
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In Case You Missed It - July 2021 Update
by Ellen Seiler Brody
Published: Tax Stringer, 07/01/2021
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Is Code Sec. 1291(f) Self-Executing?
by Michael J. Miller
Published: International Tax Journal, 03/11/2021
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Penalty Avoidance: When Can Taxpayers Rely on Their Advisors?
by Ellen Seiler Brody
Published: TaxStringer, May 1, 2020
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Will the Overlap Rule of Code Sec. 1297(d) Still Protect
by Michael J. Miller
Published: International Tax Journal, May - June 2020
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Major Tax Changes in the CARES Act
by Elliot Pisem, Ellen Seiler Brody
Published: R&H Client Letter, April 10, 2010
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New Guidance on "Hard Forks" and Changes from LIBOR
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 17, 2019
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Avoiding the "Commercial Activity" Traps for Foreign Sovereigns Investing in U.S. Real Estate
by Michael J. Miller
Published: Canadian Tax Journal, June, 2019
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Discretionary Treaty Benefits and the Unbearable Absurdity of the PPT
by Michael J. Miller
Published: International Tax Journal, May-June, 2019
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Links to the Past: Old Exceptions to New Interest Deduction Limitations
Published: Tax Notes, January 21, 2019
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The Discreet Charms of the Dividends Received Deduction
Published: Tax Notes, November 12, 2018
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Qualified Opportunity Zones and Select Partnership Issues
Published: Tax Management Real Estate Journal, November 7, 2018
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Simultaneous Equations for Simpler Tax Analysis
Published: Tax Notes, October 29, 2018
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Comments to Proposed Regulations under Section 965
Published: September 18, 2018
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Loan v. Distribution: "Illinois Tool Works v. Commissioner"
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 16, 2018
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To the Frying Pan: New Virtues of Subpart F over GILTI
Published: Tax Notes, July 2, 2018
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The End of Eternity: Anomalies in Transition to Territoriality
Published: Tax Notes, April 30, 2018
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Direct Foreign Tax Credit and GILTI: The Curious Incidence of the Credit That Was Not Cut
Published: Tax Management International Journal, April 13, 2018
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The Tax Cuts and Jobs Act - Traps for the Unwary Accountant
by Ellen Seiler Brody
Published: TaxStringer, February 1, 2018
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Foreign Corporation Not Taxable on Redemption of Partnership Interest: Tax Court Rejects Rev. Rul. 91-32
by Michael J. Miller, Ellen Seiler Brody
Published: Tax Management International Journal, August 4, 2017
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Reliance on a CPA As Reasonable Cause: "Neanatology" Lives on After "Grecian Magnesite Mining"
by Ellen Seiler Brody, Michael J. Miller
Published: Bloomberg BNA Daily Tax Report, August 3, 2017
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Tax Court Rejects Revenue Ruling 91-32 -- Holds Greek Corporation's Gain from the Redemption of Its Partnership Interest Not To Be Taxable as Effectively Connected Income
by Michael J. Miller, Ellen Seiler Brody, Mark David Rozen
Published: R&H Letter to Clients and Friends, July 24, 2017
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Eradicating Double Non-Taxation: A Comparative Analysis of the 2016 U.S. Model Income Tax Convention and OECD/G20 BEPS Action 6
by Michael S. Grisolia
Published: Bloomberg BNA Tax Management Memorandum, November 14, 2016
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Managing Global Tax Controversy: A Primer for the U.S. Multinational
by Charles S. Nelson
Published: Tax Notes, July 25, 2016
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Recent Guidance Regarding Deduction of Fines
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 16, 2016
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Snowbirds Flying Blind: Beware the US Residence Trap
by Michael J. Miller
Published: Canadian Tax Journal, August 1, 2014
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Stock Rights Under §457A: Revenue Ruling 2014-18
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 19, 2014
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Property Abandonment Results in Capital Loss: "Pilgrim's Pride"
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 20, 2014
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"Fish": Ordinary Income From Incorporation Transaction
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 19, 2013
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Options to Consider for Non-US Investors in US Real Estate
by Michael J. Miller
Published: The Canadian Tax Journal, October, 2013
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Can the Issuance of Form 1099-C Cancel a Debt?
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 15, 2013
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Expats Live in Fear of Malevolent Time Machine
by Michael J. Miller, Ellen Seiler Brody
Published: International Tax Journal, March 5, 2013
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More About Step Transactions: G.D. Parker v. Commissioner
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 20, 2012
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American Taxpayer Relief Act of 2012: International Tax Provisions
Published: R&H Letter to Clients and Friends, January 4, 2013
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IRS Provides Detailed Guidance on 2012 Offshore Voluntary Disclosure Program and Announces New Alternative Procedure for Certain Taxpayers Living Abroad
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen, Ellen Seiler Brody
Published: R&H Letter to Clients and Friends, July 3, 2012
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Foreign Asset Reporting Under Code Section 6038D
by Michael J. Miller, Ellen Seiler Brody
Published: International Tax Journal, May-April, 2012
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New Proposed Regulations Provide Some Welcome Relief for Foreign Financial Institutions under FATCA
by Mark David Rozen, Ellen Seiler Brody
Published: BNA Tax Planning International Review, March 01, 2012
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Shameful Double Taxation of Individual Expatriates
by Michael J. Miller
Published: International Tax Journal, July 01, 2011
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IRS Modifies 2011 Offshore Voluntary Disclosure Initiative to Reduce Penalties for Certain Participants and Permit Extensions
by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, June 22, 2011
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IRS Further Extends Deadline for 2009 and Prior FBARs Required to be Filed by U.S. Persons With Signature Authority but No Financial Interest in Foreign Accounts
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, June 21, 2011
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The 2011 OVDI: Is Voluntary Disclosure Really Better the Second Time Around?
by Michael J. Miller, Ellen Seiler Brody
Published: Tax Management International Journal, May 13, 2011
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Highlights of the New FBAR Regulations and Revised FBAR for 2010 Filings Due June 30, 2011
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, April 06, 2011
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Certain Taxpayers May Avoid Penalties If They File Delinquent Information Returns Relating to Foreign Accounts, Foreign Entities, and Foreign Gifts
by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, March 02, 2011
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IRS Announces 2011 Offshore Voluntary Disclosure Initiative With August 31, 2011 Deadline
by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients & Friends, February 09, 2011
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Tax Court Approves Tax-Free Payment of Outbound Guarantee Fees
by Michael J. Miller
Published: BNA Tax Management - International Journal, August 13, 2010
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2010 FBAR Update
by Michael J. Miller
Published: International Tax Journal, May 2010
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Foreign Account Tax Compliance Provisions Have Far-Reaching Effect
by Michael J. Miller, Peter H. Blessing
Published: Canadian Tax Foundation - 61st Annual Conference, April 01, 2010
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IRS Issues Relief from FBAR Filing Obligations for Three Groups
by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients & Friends, March 03, 2010
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