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“The Current State of Liquidation-Reincorporation,” 89 TAXES 25, April 2011.
April 2011
Publications
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“The Rule of Ralphs,” 2011 TNT 54-7, March 21, 2011.
March 21, 2011
Publications
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“Academic Articles on Tax,” 2011 TNT 44-11, March 7, 2011.
March 7, 2011
Publications
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“Forced Combination in North Carolina,” 2011 STN 39-29, February 28, 2011.
February 28, 2011
Publications
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“Variable Prepaid Forward or Short Against the Box or Both?” 38 DTR J-1, February 25, 2011.
February 25, 2011
Publications
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“Economic Substance Doctrine Defense Plan,” 2011 TNT 35-9, February 22, 2011.
February 22, 2011
Publications
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“Mayo Clinic Decision Does Not Insulate Treasury Regulations from Invalidation,” 21 DTR J-1, February 1, 2011.
February 1, 2011
Publications
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“Consolidating Foreign Affiliates,” 11 Fla. Tax Rev. 143, 2011.
2011
Publications
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“Circular Flows of Cash,” Tax Lawyer, Vol. 64, No. 2, 2011.
2011
Publications
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“Ownership, Series and Cells,” 2010 TNT 234-9, December 7, 2010.
December 7, 2010
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“Selling Nuclear Decommissioning Funds,” 195 DTR J-1, October 12, 2010.
October 12, 2010
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“Mergers, Reincorporations and Groman,” 128 Tax Notes 869, August 23, 2010.
August 23, 2010
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“U.S.-Headquartered Global Companies,” 127 Tax Notes 575, May 3, 2010.
May 3, 2010
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“Corporate E&P and Reorganization Boot,” 126 Tax Notes 1635, March 29, 2010.
March 29, 2010
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“The Stockless D Reorganization Regulations,” 112 JTAX96, February 2010.
February 2010
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“The New Normal: Economic Substance Doctrine First,” 126 Tax Notes 521, January 25, 2010.
January 25, 2010
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The Supreme Court's Federal Tax Jurisprudence: An Analysis of Fact Finding Methods and Statutory Interpretation from the Court's Tax Opinions, 1801-Present, ABA Section of Taxation, 2010.
2010
Publications
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"Liberalization of Rules Governing Tax-Free Reorganizations and Corporate Acquisitions Remains an Ongoing Process," BNA Daily Tax Report, No. 204, J-1, Oct. 24, 2005, ISSN 1522-8800.
October 2005
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"Legal Research in Federal Taxation," 109 Tax Notes, p. 335, Oct. 17, 2005.
October 2005
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"Chief Tax Officer Reporting Structures," The Tax Advisor, p.620, Oct. 2005.
October 2005
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"New Prop. Regs. Change Rules for Transactions Where Property of Stock Lacks Net Value," 103 Journal of Taxation, No. 1, p.14, July 2005.
July 2005
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"New Limitations on Corporate Built-In Losses," 107 Tax Notes, 1553, June 20, 2005.
June 2005
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"American Jobs Creation Act: New Section 199 Domestic Production Deduction," 16 Journal of International Tax 14, April 2005.
April 2005
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"Three New Sets of Proposed Regulations Should Make Planning for Reorganizations Much Easier," 101 Journal of Tax Notes 271, November 2004.
November 2004
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"Planning with the New Rate and Corporate Changes Made by JGTRRA," 99 Journal of Tax Notes 8, July 2003.
July 2003
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"Temporary Consolidated Return Duplicated Loss Disallowance Regulations Re-Aim at Contingent Liability Tax Shelters," 5 Business Entities 20, July/August 2003.
July/August 2003
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"The Range of Legal Opinions, with Emphasis on the 'Should' Opinion," 98 Tax Notes 1125, Feb. 17, 2003.
February 2003
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"New Temporary Regulations Issued on REIT and RIC Conversions by C Corporations," 96 Journal of Taxation 220, April 2002.
April 2002
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"Using Compensatory NQSOs and Restricted Stock with Section 355 -- New, Clear Guidance from IRS," 96 Journal of Taxation 71, February 2002.
February 2002