S Corporation Elections -- Who Decides?
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 21, 2018
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Marginal Income Tax Rates of the Passthrough Business Deduction
Published: Tax Notes, May 21, 2018
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The End of Eternity: Anomalies in Transition to Territoriality
Published: Tax Notes, April 30, 2018
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Recent Developments Regarding Contributions to Capital
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 19, 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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Corporate Tax Changes in New Tax Law
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 15, 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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Benefits & Compensation Update: President Signs H.R. 1 (Tax Cuts and Jobs Act)
by David E. Kahen
Published: Benefits & Compensation Update, December 29, 2017
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Stock Option Exercise Leading to Capital Loss: 'Hann v. United States'
by David E. Kahen
Published: New York Law Journal, December 21, 2017
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Developments Regarding Micro-Captive Insurance Structures
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 19, 2017
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Distinguishing Equity From Debt in Related Party Contexts
by David E. Kahen
Published: New York Law Journal, August 17, 2017
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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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Is New York Overreacting on Audit and Litigation of Federal Issues?
by Joseph Lipari, Ellen Seiler Brody
Published: TaxStringer, August 1, 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
Download the file for 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.
Can Capital Gain Rates Apply to Income from Phantom Stock?
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 14, 2017
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The Accumulated Earnings Tax: Back from the Grave?
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 20, 2017
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Recent Developments Relating to S Corporations
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 16, 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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Characterization of Forfeited Deposits and Break Fees
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 19, 2016
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The Ever-Expanding 'Danielson' Rule?
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 18, 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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Proposed Regulations to Treat Debt as Stock
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 21, 2016
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Receipt of "Boot" in Reorganizations: "Tseytin"
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 18, 2016
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Revisiting Allocation of Basis Issues: "Dorrance"
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 17, 2015
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What is "Insurance" for Tax Purposes?
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 15, 2015
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Decisions Tackle Corporate Equity and Compensation
by David E. Kahen
Published: New York Law Journal, August 20, 2015
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Tax Treatment When Estate Satisfies Transaction-Related Claims
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 18, 2015
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Inclusion of Refundable Tax Credits in Income
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 16, 2015
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"MoneyGram" Tackles Definition of "Bank"
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 19, 2015
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Income Classification Pitfalls for Executives of Startups
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 18, 2014
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Claim for Bad Tax Advice Results in Nontaxable Recovery
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 16, 2014
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Deductibility of Payments to Settle False Claims Act Liability
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 21, 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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Loss Deduction for Forfeiture of Insider Trading Profits
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 17, 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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Employee Benefit Plan Compliance With The Recent DOMA Supreme Court Decision
by Norman J. Misher, Allen J. Erreich, Chase B. Steinlauf
Published: R&H Letter to Clients and Friends, December 10, 2013
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Loss Disallowance for S Corp. Shareholders: 'Bronz'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 17, 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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Diverse Approaches to Allocation of Basis in Demutualizations
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 18, 2013
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Revocation of S Corp Election During Bankruptcy Upheld
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 20, 2013
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Firm Denied Current Deduction for Out-of-Pocket Disbursements
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 21, 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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Disqualification of Employee Trust: 'Yarish v. Commissioner'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 18, 2012
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The Need for a Plan: Enterprises, Inc. v. Commissioner
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 16, 2012
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Taxpayer Fights Regulations, and Wins: 'Dominion Resources'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 21, 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
Download the file for Foreign Asset Reporting Under Code Section 6038D.
'STARS' Wars -- the Service Strikes Back at Taxpayer Claims of Privilege
by Elliot Pisem
Published: Journal of Taxation, May 01, 2012
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