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Articles / Corporate Taxation

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 20, 2019
Download the file for Update on Theft Losses: 'McNely v. Commissioner'.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 18, 2019
Download the file for S Corporation Allocations Upon Transfer of Stock.
by Elliot Pisem, David E. Kahen
Published: February 21, 2019
Download the file for Value of Franchise Rights Under BIG Tax: 'H R B-Delaware v. Commissioner'.
by , By Libin Zhang (former partner at Roberts & Holland LLP)
Published: Bloomberg Insights, January 10, 2019
Download the file for Qualified Opportunity Zones: Death, Taxes, and Other Uncertainties.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 19, 2018
Download the file for Adoption and Change of Accounting Method:
Published: Tax Notes, November 12, 2018
Download the file for The Discreet Charms of the Dividends Received Deduction.
Published: Tax Management Real Estate Journal, November 7, 2018
Download the file for Qualified Opportunity Zones and Select Partnership Issues.
Published: Tax Notes, October 29, 2018
Download the file for Simultaneous Equations for Simpler Tax Analysis.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 18, 2018
Download the file for S Corporation Inconsistent Reporting Issues: 'Rubin v. United States'.
by Michael S. Grisolia
Published: Tax Notes, October 15, 2018
Download the file for Through a Glass Darkly: REIT Earnings and Profits.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 16, 2018
Download the file for Loan v. Distribution:
Published: Tax Notes, August 6, 2018
Download the file for Qualified Opportunity Zones: Hot Tubs and Other Hot Topics.
Published: Tax Notes, July 2, 2018
Download the file for To the Frying Pan: New Virtues of Subpart F over GILTI.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 21, 2018
Download the file for S Corporation Elections -- Who Decides?.
by Joshua A. Rabinovits
Published: Tax Notes, April 30, 2018
Download the file for The End of Eternity: Anomalies in Transition to Territoriality.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 19, 2018
Download the file for Recent Developments Regarding Contributions to Capital.
Published: Tax Management International Journal, April 13, 2018
Download the file for Direct Foreign Tax Credit and GILTI: The Curious Incidence of the Credit That Was Not Cut.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 15, 2018
Download the file for Corporate Tax Changes in New Tax Law.
by Ellen Seiler Brody
Published: TaxStringer, February 1, 2018
Download the file for The Tax Cuts and Jobs Act - Traps for the Unwary Accountant.
by David E. Kahen, Judy M. Hensley
Published: Benefits & Compensation Update, December 29, 2017
Download the file for Benefits & Compensation Update:  President Signs H.R. 1 (Tax Cuts and Jobs Act).
by David E. Kahen
Published: New York Law Journal, December 21, 2017
Download the file for Stock Option Exercise Leading to Capital Loss: 'Hann v. United States'.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 19, 2017
Download the file for Developments Regarding Micro-Captive Insurance Structures.
by David E. Kahen
Published: New York Law Journal, August 17, 2017
Download the file for Distinguishing Equity From Debt in Related Party Contexts.
by Michael J. Miller, Ellen Seiler Brody
Published: Tax Management International Journal, August 4, 2017
Download the file for Foreign Corporation Not Taxable on Redemption of Partnership Interest: Tax Court Rejects Rev. Rul. 91-32.
by Ellen Seiler Brody, Michael J. Miller
Published: Bloomberg BNA Daily Tax Report, August 3, 2017
Download the file for Reliance on a CPA As Reasonable Cause:
by Joseph Lipari, Ellen Seiler Brody
Published: TaxStringer, August 1, 2017
Download the file for Is New York Overreacting on Audit and Litigation of Federal Issues?.
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.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 14, 2017
Download the file for Can Capital Gain Rates Apply to Income from Phantom Stock?.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 20, 2017
Download the file for The Accumulated Earnings Tax: Back from the Grave?.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 16, 2017
Download the file for Recent Developments Relating to S Corporations.
by Michael S. Grisolia
Published: Bloomberg BNA Tax Management Memorandum, November 14, 2016
Download the file for Eradicating Double Non-Taxation: A Comparative Analysis of the 2016 U.S. Model Income Tax Convention and OECD/G20 BEPS Action 6.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 19, 2016
Download the file for Characterization of Forfeited Deposits and Break Fees.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 18, 2016
Download the file for The Ever-Expanding 'Danielson' Rule?.
by Charles S. Nelson
Published: Tax Notes, July 25, 2016
Download the file for Managing Global Tax Controversy: A Primer for the U.S. Multinational.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 16, 2016
Download the file for Recent Guidance Regarding Deduction of Fines.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 21, 2016
Download the file for Proposed Regulations to Treat Debt as Stock.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 18, 2016
Download the file for Receipt of
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 17, 2015
Download the file for Revisiting Allocation of Basis Issues:
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 15, 2015
Download the file for What is
by David E. Kahen
Published: New York Law Journal, August 20, 2015
Download the file for Decisions Tackle Corporate Equity and Compensation.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 18, 2015
Download the file for Tax Treatment When Estate Satisfies Transaction-Related Claims.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 16, 2015
Download the file for Inclusion of Refundable Tax Credits in Income.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 19, 2015
Download the file for
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 18, 2014
Download the file for Income Classification Pitfalls for Executives of Startups.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 16, 2014
Download the file for Claim for Bad Tax Advice Results in Nontaxable Recovery.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 21, 2014
Download the file for Deductibility of Payments to Settle False Claims Act Liability.
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 19, 2014
Download the file for Stock Rights Under §457A: Revenue Ruling 2014-18.