Corporate Taxation

Nancy Chassman

Partner
Tel:212-903-8767 | Email | V-Card

Ezra Dyckman

Partner
Tel:(212) 903-8785 | Email | V-Card

Stuart J. Gross

Partner
Tel:(212) 903-8723 | Email | V-Card

David E. Kahen

Partner
Tel:(212) 903-8763 | Email | V-Card

Morris L. Kramer

Partner
Tel:(212) 903-8783 | Email | V-Card

Ronald A. Morris

Counsel
Tel:(212) 903-8781 | Email | V-Card

Elliot Pisem

Partner
Tel:(212) 903-8777 | Email | V-Card

Libin S. Zhang

Partner
Tel:(212) 903-8713 | Email | V-Card

A significant part of our practice is devoted to sophisticated tax planning and solving complex corporate tax problems. We work with major multinational corporations, as well as the owners of major privately held companies to address corporate issues from the perspectives of U.S. federal, international, and state and local tax law. We represent clients in diverse industries, from telecommunications, electronics, consumer goods, transportation, power generation and manufacturing, to banking, insurance, securities, entertainment and services.

The depth and diversity of our practice allows us to maintain a leading-edge capability. We have provided strategic tax planning for major acquisitions, structured in some instances as tax-free reorganizations (mergers, reverse mergers, subsidiary-level transfers, direct stock and asset acquisitions) and in other instances as partially or fully taxable purchases. We have advised on multi-country corporate reorganizations, ESOP acquisitions, bankruptcy restructurings and leveraged buy-outs using a variety of ownership vehicles, including C corporations, partnerships, S corporations, LLCs and domestic and international joint ventures. We frequently provide tax opinions in tax-free reorganizations and, through our Washington, DC office, secure rulings and technical advice from the IRS.

We help clients develop tax strategies designed to maximize the benefits of dividend payouts, redemptions and other corporate distributions, to take advantage of the consolidated return regulations, and to minimize the impact of the loss carryover rules. We have structured spin-offs and other divisive reorganizations and devised plans to maximize the benefits of liquidations and dispositions of separate business segments. Working together with other counsel, we have also structured domestic and offshore mutual funds and REITs.

We work closely with our clients and their corporate, securities, bankruptcy, real estate, environmental, insurance, labor and other counsel to efficiently provide creative, practical tax advice on their transactions. The breadth of our exposure to sophisticated corporate transactions gives us the ability to apply that expertise beyond transactional planning, to the controversy area, where we assist clients in the conduct of tax audits, appellate reviews and litigation, at the federal, state and local level.

Financial Products
Our work in the financial products area involves a variety of instruments and structures, including, for example, floating-rate preferred stock, payment-in-kind bonds, convertible debt, and single- and multi-class trusts. We advise on the tax implications of all types of derivative products. In dealing with sophisticated products, such as variable prepaid forward contracts, off-market interest-rate swaps, dual-currency debt instruments, equity-index swaps, and contingent principal amount bonds, we have the knowledge and experience to structure the transaction to achieve the desired result relating to the amount, timing, character, and source of income and deduction.

Private Equity and Hedge Funds
Our broad exposure to all areas of taxation allows entities such as private equity and hedge funds to rely upon us for advice in a marketplace that requires immediate decisions. Executives, traders, and chief financial officers at funds we represent call us for prompt advice regarding proposed swaps, trades, and equity investments. Often, we create a tailored structure for a particular investment that takes into account not only the implications specific to the fund itself, but those that might arise for the general partner, the limited partners, and any partners with special tax status (foreign investors, tax-exempt organizations, REITs and others). We have assisted in the structuring of funds, investment management companies, general partners, and vehicles for investment by limited partners. We also help investors evaluate prospectuses of funds for possible investment, assess the tax consequences of both the overall fund strategy and investments and any possible tax considerations specific to an investor’s personal situation.

Qualified Opportunity Zones and Select Partnership Issues

by Libin S. Zhang
Published: Tax Management Real Estate Journal, November 7, 2018
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Simultaneous Equations for Simpler Tax Analysis

by Libin S. Zhang
Published: Tax Notes, October 29, 2018
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S Corporation Inconsistent Reporting Issues: 'Rubin v. United States'

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 18, 2018
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Through a Glass Darkly: REIT Earnings and Profits

by Libin S. Zhang, Michael S. Grisolia
Published: Tax Notes, October 15, 2018
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Comments to Proposed Regulations under Section 965

by Libin S. Zhang
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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Qualified Opportunity Zones: Hot Tubs and Other Hot Topics

by Libin S. Zhang
Published: Tax Notes, August 6, 2018
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To the Frying Pan: New Virtues of Subpart F over GILTI

by Libin S. Zhang
Published: Tax Notes, July 2, 2018
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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

by Libin S. Zhang
Published: Tax Notes, May 21, 2018
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The End of Eternity: Anomalies in Transition to Territoriality

by Libin S. Zhang, Joshua A. Rabinovits
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

by Libin S. Zhang
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, Judy M. Hensley
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
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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 Nancy Chassman, 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 Nancy Chassman, 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, Charles C. Shulman, Judy M. Hensley, 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
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'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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Revocation of Tax Election by Non-Debtor Declared Void

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 19, 2012
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Accrual of Deduction for Disputed Amount

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, February 16, 2012
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The Wizard of Broz: S Corporations, Economic Outlay, and Debt Basis

by Elliot Pisem, Libin S. Zhang
Published: Journal of Taxation, February 01, 2012
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Warrants and Tax Avoidance Motivation Prove Hazardous

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, October 20, 2011
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The New Voluntary Disclosure: No, It's Not For Those Hidden Foreign Bank Accounts -- This Time It's For Employers Who Need to Reclassify Their Workers As Employees

by Norman J. Misher, Allen J. Erreich, Ellen Seiler Brody
Published: R&H Letter to Clients and Friends, October 19, 2011
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Noncompetition Covenants: 'Recovery Group v. Commissioner'

by David E. Kahen, Elliot Pisem
Published: New York Law Journel, August 18, 2011
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Transferee Liability: Recent Developments

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, April 21, 2011
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Substance Over Form - 'WB Acquisitions'

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, February 17, 2011
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Court of Federal Claims Splits on the Computation of the TEFRA 'Jurisdictional Deposit'

by Elliot Pisem
Published: Journal of Taxation, February 01, 2011
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Reliance On Tax Opinion May Not Prevent Penalties

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, December 16, 2010
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Lack of Consistency in S Corporation Reporting -- How Onerous Are the Results?

by Elliot Pisem
Published: Journal of Taxation, December 01, 2010
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Rules Address Reporting of Securities Transactions

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, October 21, 2010
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Tax Court Decision Clarifies Treatment of Built-In Gain

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, August 19, 2010
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The Requirement For a Deficiency Notice -- When an Absolute Provision Is Not Always Absolute

by Ellen Seiler Brody
Published: Journal of Taxation, August 01, 2010
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Sales-Based Contingent Royalties Are Not a Production Cost Capitalized Under Section 263A

by Elliot Pisem
Published: Journal of Taxation, July 01, 2010
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What is (Not) Income? Nathel v. Commissioner

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, June 17, 2010
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Ruling Illustrates Treatment of Payments to Settle Litigation

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, April 15, 2010
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Drawing a Line -- Information Reporting vs. Malicious Gossip

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, December 17, 2009
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IRAs Barred From Owning Stock in S Corporation

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, October 15, 2009
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Gratuitous Transfer to Related Partnership Not a 'Distribution'

by David E. Kahen
Published: New York Law Journal, June 18, 2009
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Court Addresses 'Reasonableness' of Compensation

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 16, 2009
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Allocations of Consideration for a Closely Held Business - Muskat v. United States

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 18, 2009
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Private Equity Fund Found Liable for Pension Obligation of Bankrupt Portfolio Company

by Norman J. Misher
Published: The Journal of Private Equity, January 01, 2009
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Proposed Regulations Clarify Penalty Taxes on Income Inclusions

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, December 18, 2008
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Ruling Highlights Importance of Drafting to Indemnification

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, October 16, 2008
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New Legislation Penalizes Deferred Compensation from Certain Foreign Corporations and Partnerships

by David E. Kahen, Norman J. Misher
Published: R&H Letter to Clients and Friends, October 15, 2008
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Decisions Underline Scope of IRS Summons Power

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, August 21, 2008
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Shareholder Disputes Give Rise to Tax Disputes

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, June 19, 2008
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The Short-Term Deferral Rule Can Mitigate the Impact of Section 409A

Published: R&H Letter to Clients and Friends, June 11, 2008
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What Happened to My Prepayment Forum? The Penalty Problem in TEFRA Partnership Audit Cases

by Elliot Pisem
Published: Journal of Taxation, May 01, 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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Time To Comply With Section 409A Is Running Out

Published: R&H Letter to Clients and Friends, April 02, 2008
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Ernst & Young: When Must Stocks Be Taken Into Income?

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 21, 2008
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Ruling Has Not Resolved Work-Product Privilege Issue

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, October 18, 2007
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Recent Developments Related To Nontaxable Spinoffs

by Elliot Pisem, David E. Kahen
Published: The New York Law Journal, August 16, 2007
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Warrants Not Received 'In Connection With' Performance of Services

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, June 21, 2007
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The Burden of Persuasion in Tax Litigation

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, December 21, 2006
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Court Addresses Limitations on Pass-Through of Losses

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, August 17, 2006
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Applying Section 162(m) To Partnership Remuneration

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 20, 2006
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State Corporate Income Taxes No Longer Make Sense

by , Carolyn Joy Lee
Published: State Tax Notes, April 17, 2006
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When Is A Contract An Option?

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, December 15, 2005
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Gain Clarified in Shareholder Loans to S Corporations

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 20, 2005
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Is Evading Foreign Taxes A U.S. Crime?

Published: The Metropolitan Corporate Counsel, September 01, 2005
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Impact of Securities Laws on Taxation of Compensation

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 18, 2005
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IRS Shines Spotlight On Executive Compensation Practices

by David E. Kahen
Published: The Metropolitan Corporate Counsel, July 01, 2005
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New IRS Rules on Written Tax Advice

Published: R&H Letter to Clients and Friends, June 08, 2005
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How Many Tax Opinions Will You Need: And Where Will You Get Them?

by Elliot Pisem
Published: The Metropolitan Corporate Counsel, May 01, 2005
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Formation, Reorganization, Liquidation of Insolvent Corporations

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 21, 2005
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Should Accounting Firms Be Tax Advisors?

Published: The Metropolitan Corporate Counsel, March 01, 2005
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Redemption of Stock in Family-Owned Corporation

by Elliot Pisem, David E. Kahen
Published: The New York Law Journal, February 17, 2005
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Deductibility Limits on Accrued Interest to Related Parties

by Elliot Pisem, David E. Kahen
Published: The New York Law Journal, December 16, 2004
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A Tax Opinion Is Not A Bulletproof Vest

by Richard A. Levine
Published: The Metropolitan Corporate Counsel, November 01, 2004
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There's No Guarantee: Proposed Regulations on Wholly-Owned LLCs

by Ezra Dyckman, Ronald A. Morris
Published: New York Law Journal, October 27, 2004
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Exchanges of Short-Term Debt Instruments in Reorganizations

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, August 19, 2004
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Give and Take -- New Federal, State and City Tax Legislation

by Ezra Dyckman, Ronald A. Morris
Published: New York Law Journal, June 25, 2004
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'Dover' and the Consequences of Check-the-Box Liquidations

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 17, 2004
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Awarding Scholarships and Disaster Relief to Employees

by JoAnn Luehring
Published: The Metropolitan Corporate Counsel, June 01, 2004
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Treatment of Contingent Liabilities Assumed in Purchase of Assets

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 19, 2004
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Roberts & Holland: The Largest Tax Boutique in The Country

by Lary S. Wolf
Published: The Metropolitan Corporate Counsel, January 01, 2004
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New Guidance Regarding Tax Treatment of Deemed Liquidations

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 18, 2003
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Mirror, Mirror on the Wall: When a Liability Is an Asset

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 16, 2003
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Reduction of Tax Attributes Following Cancellation of Debt

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 21, 2003
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Requirements for Spinoff Transactions

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 19, 2003
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Transfers to RICs and REITs

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 17, 2003
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New Proposed Rules Will Change Tax Treatment of Acquisition Costs

by Elliot Pisem, David E. Kahen
Published: The Metropolitan Corporate Counsel, March 01, 2003
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New Regulations Regarding Treatment of Transaction Costs

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 20, 2003
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Disclosures Required on 2002 Tax Returns

by Elliot Pisem
Published: R & H Letter to Clients and Friends, January 10, 2003
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Privilege in Tax Matters: Your Accountant v. Your Lawyer?

by Elliot Pisem
Published: The Metropolitan Corporate Counsel, January 01, 2003
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Further Liberalization of Requirements for Corporate Reorganization

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 19, 2002
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IRS Settlement Initiatives Relating to Tax Shelters

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 17, 2002
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Active Trade or Business Requirements for Nontaxable Spin Offs - Rev. Rul. 2002-49

by Elliot Pisem, David E. Kahen
Published: The New York Journal, August 15, 2002
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When Should a Distribution Be Taxed As an Exchange? -- 'Steel v. Commissioner'

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 20, 2002
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Accounting for Prepaid Items: 'U.S. Freightways v. Commissioner'

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, April 18, 2002
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The "Device" Test for Spinoffs Under Section 355

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 14, 2002
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The Hazards of (Mis)Allocation of Purchae Price

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 20, 2001
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Step Transactions and Mergers: Rev. Rul. 2001-46

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 18, 2001
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"Rite Aid": Consolidated Return Loss Disallowance Held Invalid

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 16, 2001
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New Rulings Regarding Corporate Reorganizations

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 21, 2001
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Stock Redemption or Payment of Compensation?

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 19, 2001
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Installment Method Reinstated for Accrual-Method Taxpayers

by Ronald A. Morris, Ezra Dyckman
Published: New York Law Journal, February 28, 2001
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Supreme Court Addresses Discharge of Debt Income for S Corporation in "Gitlitz"

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 15, 2001
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What's the Option Worth?

by Elliot Pisem
Published: New York Law Journal, August 17, 2000
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When Is a Merger Not a Merger?

by Elliot Pisem
Published: New York Law Journal, June 15, 2000
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Rules for Product Liability Losses for Consolidated Groups

by Elliot Pisem, Ellen Seiler Brody
Published: New York Law Journal, April 20, 2000
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Important New Rules on QSubs

by Elliot Pisem, Ronald A. Morris, Ellen Seiler Brody
Published: R & H Letter to Clients & Friends, February 28, 2000

Conversion of Corporations to RICs and REITs

by Elliot Pisem, Ezra Dyckman
Published: New York Law Journal, February 17, 2000
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IRS Scrambling to Attack Lease Strips

by Joseph Lipari
Published: Tax Management International Journal, January 14, 2000

Ticket to Work and Work Incentives Act of 1999

by Elliot Pisem, Ezra Dyckman
Published: New York Law Journal, December 23, 1999
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Tax Law's Insolvency Definition Not the Same as Bankruptcy's

by Elliot Pisem
Published: New York Law Journal, October 12, 1999
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New Rules for Purchase Price Allocations in Taxable "M&A" Transations

by Elliot Pisem
Published: New York Law Journal, August 19, 1999
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Treasury Brings "Fast Pay" Arrangements to a Screeching Halt

by Elliot Pisem
Published: New York Law Journal, June 19, 1999
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Administration Proposals: Tax Avoidance and Corporate Tax Shelters

by Elliot Pisem
Published: R & H Newsletter -- Tax Insights, February 28, 1999

Mergers and Aquisitions from A to Z -- State and Local Tax Considerations

by , Carolyn Joy Lee
Published: PLI - Mergers & Acquisitions 1999, January 11, 1999

Bankruptcy Code Trumps Internal Revenue Code

by Elliot Pisem, Ellen Seiler Brody
Published: New York Law Journal, December 24, 1998
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Laidlaw Taxpayer Crashed and Burned, Losing Billion-Dollar Debt-Equity Case

by Sanford H. Goldberg, Peter A. Glicklich
Published: Canadian Tax Journal, December 01, 1998

Just When You Thought It Was Safe to Go Back in the Water: Recharacterizing Debt as Equity

by Elliot Pisem
Published: New York Law Journal, August 27, 1998
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QSSS Election -- Proposed Regulations Regarding S Corporation Subsidiaries

by Ronald A. Morris, David E. Kahen
Published: New York Law Journal, June 24, 1998
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Selling Closely-Held Stock to an Employee Stock Ownership Plan -- How Adequate Must the Consideration Be?

by Elliot Pisem, Allen J. Erreich
Published: New York Law Journal, April 23, 1998
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Identifying the Real Owner -- Tax Court Revisits Grants of Reciprocal Put and Call Options

by Ronald A. Morris, David E. Kahen
Published: New York Law Journal, December 24, 1997
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To Vote or Not to Vote, That Is the Question

by Elliot Pisem, Quincy Cotton
Published: New York Law Journal, October 23, 1997
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Corporate Provisions of the Taxpayer Relief Act of 1997

by Elliot Pisem
Published: New York Law Journal, August 28, 1997
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Employee Sells a Home and Employer Gets a Tax Deduction

by Elliot Pisem, Ellen Seiler Brody
Published: New York Law Journal, June 26, 1997
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Rules on Below-Market and Interest-Free Loans

by Elliot Pisem
Published: New York Law Journal, April 24, 1997
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Continuity of Interest Rules May Be Liberalized -- But Can Remain a Trap for the Unwary

by Elliot Pisem, Ellen Seiler Brody
Published: New York Law Journal, February 27, 1997
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'Check-the-Box' Regulations Provide Certainty, Flexibility and New Planning Opportunities

by Elliot Pisem, Lary S. Wolf, Peter A. Glicklich
Published: R & H Newsletter -- Tax Insights, January 01, 1997