Reflections on the Application of Income Tax Treaties to Hybrid Entities That Earn Non-FDAP Income
by Michael J. Miller
Published: International Tax Journal, January 01, 2010
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IRS Extends Deadline For Voluntary Disclosure Program
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, September 24, 2009
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Taxpayers Still Have Time to Resolve Offshore Tax Issues Through the Voluntary Disclosure Program
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, July 22, 2009
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Should Retirees Still Consider Expatriating?
by Ellen Seiler Brody
Published: Journal of Retirement Planning, May 01, 2009
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Proposed Legislation Affecting Assets Held Overseas
by Mark David Rozen, Ellen Seiler Brody
Published: Rothschild Trust Review, April 01, 2009
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U.S. Adopts Exit Tax Upon Expatriation
by Ellen Seiler Brody
Published: BNA Tax Planning International Review, December 16, 2008
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Forfeiture of Deductions for Failure to File Timely Return: (Swallows Holding, Ltd. v. Commissioner)
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, April 17, 2008
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Proposed Earnings-Stripping Rules May Affect Canadian Investments in the United States
by Michael J. Miller
Published: The Canadian Tax Journal, September 01, 2007
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Accessing U.S. Income Tax Treaties: Current Trends in the Limitation on Benefits Article
by Michael J. Miller
Published: International Tax Journal, June 01, 2007
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Notice 2007-13 Announces New and Improved Substantial Assistance Rules
by Michael J. Miller
Published: Tax Management International Journal, April 13, 2007
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Proposed Regulations 'Clarifying' the Technical Taxpayer Rule Don't Pass the Giggle Test
by Howard J. Levine, Michael J. Miller
Published: International Tax Journal, February 01, 2007
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Cleansing the PFIC Taint Just Got Easier: New Regulations Permit Purging Elections for Closed Years
by Michael J. Miller
Published: Tax Management Memorandum, April 03, 2006
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CA-2's Narrow View of Pasquantino Does Not Affect Enlarged Scope of Federal Fraud and Money Laundering
by , Abraham Leitner
Published: Journal of Taxation, January 15, 2006
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Are Your Non-U.S. Executives Prepared for U.S. Estate Tax?
by Quincy Cotton
Published: The Metropolitan Corporate Counsel, December 01, 2005
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Recent Developments Make It Easier For U.S.-Based Multinationals To Dispose Of Foreign Subsidiaries
by , Abraham Leitner
Published: Canadian Tax Journal, March 01, 2005
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A One-Time Tax Break For US Multinationals
by , Abraham Leitner
Published: The Metropolitan Corporate Counsel, January 01, 2005
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Pending Protocol Will Prevent Inverted Corporations from Accessing the Barbados Treaty
by Michael J. Miller
Published: Tax Management International Journal, November 12, 2004
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American Jobs Creation Act of 2004 International Tax Provisions
by Mark David Rozen, Joseph Lipari, Michael J. Miller
Published: R & H Letter to Clients and Friends, November 11, 2004
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Treaty Conflicts in Categorizing Income as Business Profits Caused by Differences in Approach between Common Law and Civil Law
by , John Avery Jones
Published: Bulletin for International Fiscal Documentation, November 01, 2004
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Avoiding U.S. Tax On Foreign Sales To U.S. Customers
by Howard J. Levine, Michael J. Miller
Published: The Metropolitan Corporate Counsel, October 01, 2004
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IRS Issues A Warning To Canadian Law Firms With U.S. Branch Offices
by Michael J. Miller
Published: The Canadian Tax Journal, March 01, 2004
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Proposed Amendment to FIRPTA Could Make U.S. REITs More Attractive to Canadian Real Estate Investors
by Mark David Rozen, Abraham Leitner
Published: The Canadian Tax Journal, March 01, 2004
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U.S. Reduced Rates Now Apply to Dividends of Non-Corporate Taxpayers
by , Peter A. Glicklich, Abraham Leitner
Published: The Canadian Tax Journal, September 01, 2003
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September 15th Due Date for Waiver of Filing Deadline for Foreign Taxpayers
by Mark David Rozen, Michael J. Miller
Published: R&H Letter to Clients and Friends, August 14, 2003
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Gain Recognition Agreement Regulations Could Stand Some Clarification
by , Peter A. Glicklich, Abraham Leitner
Published: Taxation of Global Transactions, June 01, 2003
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Proposed Transportation Regulations - Suggestions for Final Course Correction
by Michael J. Miller
Published: Tax Management International Journal, May 09, 2003
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Interest Stripping Changes Affecting U.S. Corporations Seem Likely; Only the Details Remain Opaque
by , Peter A. Glicklich, Abraham Leitner
Published: The Canadian Tax Journal, February 01, 2003
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FSA 200220005: IRS Again Attempts to Void Contract Manufacturing Arrangements Under Subpart F
by Howard J. Levine, Peter A. Glicklich
Published: Taxation of Global Transactions, December 01, 2002
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Thomas Bill Currently Pending in Congress Includes Many Important Foreign Tax and Other Legislative Proposals
by , Peter A. Glicklich, Abraham Leitner
Published: The Canadian Tax Journal, December 01, 2002
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Final Regulations on Payments by 'Reverse Hybrid' U.S. Entities Include Narrow Limits on Treaty Use
by , Peter A. Glicklich, Abraham Leitner
Published: The Canadian Tax Journal, September 01, 2002
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Estate Tax Conflicts Resulting from a Change in Residence
Published: International Fiscal Association -- 56th Congress, August 25, 2002
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Gains Tax vs. Inheritance Tax
Published: International Fiscal Association -- 56th Congress, August 25, 2002
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Electronic Arts: Taxpayers Appear to Win a Battle on the Subpart F Contract Manufacturing Front
by Howard J. Levine, Peter A. Glicklich
Published: Taxation of Global Transactions, August 15, 2002
IRS Wields the Two-Edged Sword of Code Sec. 956
by Howard J. Levine, Peter A. Glicklich
Published: Taxation of Global Transactions, April 15, 2002
U.S. Export Taxation, Treaty Challenges, and Filing Leniency Bear Watching
by Michael J. Miller, Peter A. Glicklich
Published: Canadian Tax Journal, March 15, 2002
'Textron' Makes for Mischief: Tax Court Opens a Pandora's Box
by Howard J. Levine, Peter A. Glicklich
Published: Taxation of Global Transactions, January 15, 2002
What to Expect in the New US-Canada Treaty
by Michael J. Miller, Peter A. Glicklich
Published: Canadian Tax Journal, December 15, 2001
Accessing the Manufacturing Exception to Subpart F Through Contract Manufacturing Arrangements
by Howard J. Levine, Michael J. Miller, Peter A. Glicklich
Published: Journal of Taxation of Global Transactions, December 01, 2001
U.S. Taxation of E-Commerce under Subpart F -- Missing Pieces Leave Uncertainty
by , Peter A. Glicklich, Abraham Leitner
Published: 2001 International Bureau of Fiscal Documentation, October 15, 2001
Appeals Court Invalidates US-Netherlands 'Double-Dip' Financing Structure
by Michael J. Miller, Peter A. Glicklich
Published: Canadian Tax Journal, October 01, 2001
IRS Proposes Regulations on Treaty Benefits for Payments by 'Reverse Hybrid' US Entities
by Michael J. Miller, Peter A. Glicklich
Published: Canadian Tax Journal, June 01, 2001
Considerations for Underlying Foreign Corporations
Published: ALI-ABA Estate Planning Course Materials Journal, April 30, 2001
Appeals Court Adheres To Precedent, Tells IRS That It's Too Late To Issue Regulations
by Michael J. Miller, Peter A. Glicklich
Published: Canadian Tax Journal, February 01, 2001
Transfers to Foreign Trusts: Treasury Proposes Regulations Under ยงยง679 and 684
by Joseph Lipari, Quincy Cotton
Published: Tax Management International Journal, January 12, 2001
Taxation Caused by or After a Change in Residence
Published: Tax Notes International, August 07, 2000
New U.S. Withholding Rules for Hybrids and Passthroughs
by Ellen Seiler Brody, Peter A. Glicklich
Published: Canadian Tax Journal, June 01, 2000
When Does E-Commerce Result in a Permanent Establishment? The OECD's Initial Response
by Howard J. Levine
Published: Tax Management International Journal, April 14, 2000
Update of Recent Actions by U.S. Taxing Authorities
by Ellen Seiler Brody, Peter A. Glicklich
Published: Canadian Tax Journal, March 01, 2000
IRS Scrambling to Attack Lease Strips
by Joseph Lipari
Published: Tax Management International Journal, January 14, 2000
U.S. Court Finds Foreign Tax Credit Strip Does Not Compute
by , Peter A. Glicklich, Abraham Leitner
Published: Canadian Tax Journal, December 01, 1999