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August 2012
Publications
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"FATCA Made Easy?" Tax Management International Journal, Vol. 41, No. 5, May 11, 2012.
May 11, 2012
Publications
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"Dividend Distributions versus Ordinary Income Inclusions: Rodriguez v. Comr.," Tax Management International Journal, Vol. 41, No. 3, March 9, 2012.
March 9, 2012
Publications
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"The Tax Basics of Outbound Domestic Liquidations Under §367(e)(2)," Tax Management International Journal, Vol. 40, No. 12, December 9, 2011.
December 9, 2011
Publications
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“The Annual Stop Tax Haven Abuse Act Show,” Tax Management International Journal, Vol. 40, No.9, September 9, 2011.
September 9, 2011
Publications
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“Whistle While You Work: The Characterization and Sourcing of Whistleblower Awards,” Tax Management International Journal, Vol. 40, No. 8, August 12, 2011.
August 12, 2011
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“The Final Word on the F Word: FBAR,” Tax Management International Journal, Vol. 40, No. 6, June 10, 2011.
June 10, 2011
Publications
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“Consignments versus Agencies: Avoiding Permanent Establishments,” Tax Management International Journal, Vol. 40, No. 4, April 8, 2011.
April 8, 2011
Publications
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“Limitations on Treaty Benefits: A Narrow Escape (H.R. 847) – But Here We Go Again (H.R. 64),” Tax Management International Journal, Vol. 40, No. 2, February 11, 2011.
February 11, 2011
Publications
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“FATCA: We Want More! Preliminary Guidance Issued – Notice 2010-60,” Tax Management International Journal, Vol. 39, No. 11, November 12, 2010.
November 12, 2010
Publications
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“From Russia With Love: Global Service Partnerships – PLR 201028026 and PLR 201028027,” Tax Management International Journal, Vol. 39, No. 10, October 8, 2010.
October 8, 2010
Publications
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“Again? H.R. 5328: International Tax Competitiveness Act of 2010,” Tax Management International Journal, Vol. 39, No. 8, August 13, 2010
August 13, 2010
Publications
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"More on the 'F' Word: FBAR," Tax Management International Journal, Vol. 39, No. 6, June 11, 2010.
June 11, 2010
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"Putting Symmetry into Your §304 Life," Tax Management International Journal, Vol. 39, No. 3, March 12, 2010.
March 12, 2010
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"More on Individual Expatriation: Notice 2009-85," Tax Management International Journal, Vol. 39, No. 2, February 12, 2010.
February 12, 2010
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"More International Tax Enforcement: Leading with the Foreign Account Tax Compliance Act of 2009," Tax Management International Journal, Vol. 38, No. 12, December 11, 2009.
December 11, 2009
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"President Obama's International Tax Enforcement Proposals: Analysis and Critique," Tax Management International Journal, Vol. 38, No. 10, October 9, 2009.
October 9, 2009
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"Corporate Inversions -- Round Four: The New -2T Regulations," Tax Management International Journal, Vol. 38, No. 9, September 11, 2009.
September 11, 2009
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"U.S. Tax Enforcement Measures -- An Update on Current and Proposed Efforts," Tax Management International Journal, Vol. 38, No. 7, July 10, 2009.
July 10, 2009
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"Closing Yet Another Repatriation Loophole in Related-Party Cross-Border Stock Transfers -- §§367/304," Tax Management International Journal, Vol. 38, No. 6, June 12, 2009.
June 12, 2009
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"Corporate Expatriation Again?" Tax Management International Journal, Vol. 38, No. 4, April 10, 2009.
April 10, 2009
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"Attack on Hedge Funds and Much More: New §457A," Tax Management International Journal, Vol. 38, No. 2, February 13, 2009.
February 13, 2009