2007
Taxes - The Tax Magazine (CCH)
Imperfections of Competent Authority Relief (with John McDonald)
2004
Taxes - The Tax Magazine (CCH)
Rev. Rul. 2003-125: IRS Rules Check-the-Box Election Is Identifiable Event for Worthless Stock Loss Purposes (with John McDonald)
2004
Taxes - The Tax Magazine (CCH)
New Order: Proposed Regulations Alter “Developer-Assister” Regime for Ownership of Intangible Property (with John McDonald)
2003
Taxes - The Tax Magazine (CCH)
Characterization and Foreign Tax Credit Issues in Certain Post-Closing Integration Transactions
2003
Taxes - The Tax Magazine (CCH)
To File or Not to File: The Interaction of Code Sec. 367(a) and Code Sec. 304
2003
Taxes - The Tax Magazine (CCH)
Boeing Co.: The Supreme Court Interprets the R&D Apportionment Regulations (with John McDonald)
2003
Taxes - The Tax Magazine (CCH)
Rolling with the Changes: The IRS Provides Guidance on Transition Rule for 10/50 Basket Credit (with John McDonald)
2003
Taxes - The Tax Magazine (CCH)
Interest Apportionment Rules Can Double-Count Foreign Source Assets in Certain Joint Venture Transactions (with John McDonald)
2003
Taxes - The Tax Magazine (CCH)
Notice 2003-46: The Extraordinary Transaction Regulations Are Withdrawn (with John McDonald)
2002
Journal of International Taxation
DHL: Ninth Circuit Sheds Very Little Light on Bright-Line Test (with Marc Levey, Lawrence Shapiro, Robert Cunningham and William Garofalo)
2002
Taxes - The Tax Magazine (CCH)
Taxpayers are Permitted to Structure Cost-Sharing Buy-in Payments as Royalties (with John McDonald)
2002
Taxes - The Tax Magazine (CCH)
IRS Applies Step-Transaction Principles to Force Recognition of Subpart F Income
2002
Taxes - The Tax Magazine (CCH)
FSA 200220005: The IRS Attacks Contract Manufacturing, (with John McDonald)
2002
Taxes - The Tax Magazine (CCH)
Foreign Source Income from Maquiladora Operations (with John McDonald)
2002
Taxes - The Tax Magazine (CCH)
Foreign Source Income from Maquiladora Operations (with John McDonald);
2002
Taxes - The Tax Magazine (CCH)
Taxable Inversion Transactions (with John McDonald)
2002
Taxes - The Tax Magazine (CCH)
Cross-Border Hybrid Instruments (Redux) (with John McDonald)
2001
Taxes - The Tax Magazine (CCH)
Proposed Regulations Regarding Domestic Reverse Hybrid Entities (with John McDonald)
2001
Taxes - The Tax Magazine (CCH)
Medchem (P.R.) Inc.: The Confused State of Contract Manufacturing (with John McDonald)
2001
Taxes - The Tax Magazine (CCH)
Cross-Border Hybrid Instruments (with John McDonald)
2001
Taxes - The Tax Magazine (CCH)
New Proposed Code Sec. 367(b) Regulations Govern the Carryover of Tax Attributes in Reorganizations Involving Foreign Corporations (with John McDonald)
2000
Taxes - The Tax Magazine (CCH)
Notice 2000-20: Branch Currency Translation Gains and Losses (with John McDonald)
2000
Taxes - The Tax Magazine (CCH)
Final Code Sec. 894 Regulations: Treaty Benefits for Hybrid Entity Payments (with John McDonald)
2000
Taxes - The Tax Magazine (CCH)
Finally Finalized: IRS Issues Final Regulations Under Code Section 367(b) (with John McDonald)
2000
Taxes - The Tax Magazine (CCH)
Tax Court Attributes Contract Manufacturer’s Activities to Principal (with John McDonald)
1999
Taxes - The Tax Magazine (CCH)
The Real World of Transfer Pricing Today
1998
Taxes - The Tax Magazine (CCH)
New Code Sec. 367 Regulations
1998
Taxes - The Tax Magazine (CCH)
Contract Manufacturing: Rev. Rul. 97-48 Revokes Rev. Rul. 75-7
1998
Taxes - The Tax Magazine (CCH)
The IRS Targets Perceived International Tax Abuses
1998
Taxes - The Tax Magazine (CCH)
Fiscally Transparent Subpart F
1998
Taxes - The Tax Magazine (CCH)
The Introduction of a Single European Currency
1998
Taxes - The Tax Magazine (CCH)
Single-Member Foreign Entities
1996
Miami Inter-American Law Review
U.S. Tax Planning for U.S. Companies Doing Business in Latin America (with Robert F. Hudson)
1995
Taxes - The Tax Magazine (CCH)
Using Partnerships in International Tax Planning
1994
Taxes - The Tax Magazine (CCH)
Intercompany Pricing: Getting It Right and What Happens If You Don't (panel discussion)
1994
INTERNATIONAL TRANSFER PRICING LAWS: TEXT AND COMMENTARY
(Loose leaf service published by CCH in December 1994 and updated quarterly)
1989
Taxes - The Tax Magazine (CCH)
International Mergers and Acquisitions (with Debra Falduto Novack)