| Rev. Rul. 2003-125: IRS Rules Check-the-Box Election Is Identifiable Event for Worthless Stock Loss Purposes (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2004 |
| To File or Not to File: The Interaction of Code Sec. 367(a) and Code Sec. 304 |
Taxes - The Tax Magazine (CCH) |
2003 |
| Characterization and Foreign Tax Credit Issues in Certain Post-Closing Integration Transactions |
Taxes - The Tax Magazine (CCH) |
2003 |
| Boeing Co.: The Supreme Court Interprets the R&D Apportionment Regulations (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2003 |
| Rolling with the Changes: The IRS Provides Guidance on Transition Rule for 10/50 Basket Credit (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2003 |
| Interest Apportionment Rules Can Double-Count Foreign Source Assets in Certain Joint Venture Transactions (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2003 |
| Notice 2003-46: The Extraordinary Transaction Regulations Are Withdrawn (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2003 |
| Cross-Border Hybrid Instruments (Redux) (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2002 |
| Taxable Inversion Transactions (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2002 |
| Foreign Source Income from Maquiladora Operations (with John McDonald); |
Taxes - The Tax Magazine (CCH) |
2002 |
| Foreign Source Income from Maquiladora Operations (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2002 |
| FSA 200220005: The IRS Attacks Contract Manufacturing, (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2002 |
| IRS Applies Step-Transaction Principles to Force Recognition of Subpart F Income |
Taxes - The Tax Magazine (CCH) |
2002 |
| DHL: Ninth Circuit Sheds Very Little Light on Bright-Line Test (with Marc Levey, Lawrence Shapiro, Robert Cunningham and William Garofalo) |
Journal of International Taxation |
2002 |
| Taxpayers are Permitted to Structure Cost-Sharing Buy-in Payments as Royalties (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2002 |
| New Proposed Code Sec. 367(b) Regulations Govern the Carryover of Tax Attributes in Reorganizations Involving Foreign Corporations (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2001 |
| Proposed Regulations Regarding Domestic Reverse Hybrid Entities (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2001 |
| Medchem (P.R.) Inc.: The Confused State of Contract Manufacturing (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2001 |
| Cross-Border Hybrid Instruments (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2001 |
| Tax Court Attributes Contract Manufacturer’s Activities to Principal (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2000 |
| Finally Finalized: IRS Issues Final Regulations Under Code Section 367(b) (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2000 |
| Final Code Sec. 894 Regulations: Treaty Benefits for Hybrid Entity Payments (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2000 |
| Notice 2000-20: Branch Currency Translation Gains and Losses (with John McDonald) |
Taxes - The Tax Magazine (CCH) |
2000 |
| The Real World of Transfer Pricing Today |
Taxes - The Tax Magazine (CCH) |
1999 |
| Contract Manufacturing: Rev. Rul. 97-48 Revokes Rev. Rul. 75-7 |
Taxes - The Tax Magazine (CCH) |
1998 |
| The IRS Targets Perceived International Tax Abuses |
Taxes - The Tax Magazine (CCH) |
1998 |
| Fiscally Transparent Subpart F |
Taxes - The Tax Magazine (CCH) |
1998 |
| The Introduction of a Single European Currency |
Taxes - The Tax Magazine (CCH) |
1998 |
| New Code Sec. 367 Regulations |
Taxes - The Tax Magazine (CCH) |
1998 |
| Single-Member Foreign Entities |
Taxes - The Tax Magazine (CCH) |
1998 |
| U.S. Tax Planning for U.S. Companies Doing Business in Latin America (with Robert F. Hudson) |
Miami Inter-American Law Review |
1996 |
| Using Partnerships in International Tax Planning |
Taxes - The Tax Magazine (CCH) |
1995 |
| Intercompany Pricing: Getting It Right and What Happens If You Don't (panel discussion) |
Taxes - The Tax Magazine (CCH) |
1994 |
| (Loose leaf service published by CCH in December 1994 and updated quarterly) |
INTERNATIONAL TRANSFER PRICING LAWS: TEXT AND COMMENTARY |
1994 |
| International Mergers and Acquisitions (with Debra Falduto Novack) |
Taxes - The Tax Magazine (CCH) |
1989 |
