Publications: Corporate Tax

IRS Provides Relief to Domestic Partnerships Caught in GILTI Conundrum
IPB Tax Insider, 08.28.2019
With Altera Appeal Still Pending, IRS Signals Intent to Re-Open Audits of Cost-Sharing Issue
IPB Tax Insider, 08.08.2019
IPB Alert: Notice 2019-09 and Section 4960
04.02.2019
"The Problem With Wearing Two Hats"
Tax Notes, 11.06.2017
Heléna Klumpp Published in CFO.com re: Partnership Agreements
CFO.com, 09.06.2017
Heléna Klumpp Published in Tax Notes
Tax Notes Special Report, 06.26.2017
"The Saga of Unfulfilled Business Income Tax Reform"
Temple Law Review, Winter 2017
"Gain in Marketable Securities Should Be Taxed at Death"
Tax Notes, 03.13.2017
Heléna Klumpp Quoted in "Planning for Tax Policy Turmoil"
CFO Magazine, 02.28.2017
Ivins Attorney Doug Andre Quoted Regarding Expatriation
BloombergBNA Daily Tax Report, 02.09.2017
Reclassifying Section 174 Costs - Amended Returns versus Form 3115
IP&B Tax Insider, 02.06.2017
"How the Election May Affect the Taxation of Business Income"
journalofaccountancy.com, 01.2017
Heléna Klumpp Quoted in "Tax Implications of the Trump Administration"
U.S. News & World Report, 01.19.2017
Final Regulations Issued for Foreign-Owned Disregarded Entities
Corporate Tax Insider, 12.22.2016
Marvel and United Dominion's Dangerous Dictum
TaxNotes, 10.10.2016
Heléna Klumpp Quoted in "House Republicans Propose New Tax Blueprint"
Talking Tax Podcast (Bloomberg BNA), 09.18.2016
"IRS Guidance Tightens Inversions Rules Awaiting Tax Reform"
Daily Tax Report, 05.23.2016
"Defending Transfer Pricing Audits Under the IRS's New Roadmap"
Tax Notes, April 28, 2014
Deploying Company Foundations in Battle for Tech Talent
The Tax Executive, 04.06.2016
Standing Issues in Direct APA Challenges to Tax Regulations
Tax Notes, 11.23.2015
"Coming Conflicts: Proposed U.S. Transfer Pricing Services Regulations and the Treatment of Intangibles"
6 Derivatives and Financial Instruments No. 5, September 30, 2004
Patrick Smith Recently on List of Top Ten Downloads for U.S. Administrative Law e-Journal
08.21.2015
Pat Smith's Two-Part Blog on Florida Bankers Association v. Treasury Department Featured in Procedurally Taxing
Procedurally Taxing, 08.18.2015
Ivins Attorney Pat Smith's Recent Blog Post on Altera Decision
Yale Journal on Regulation, 08.06.2015
Pat Smith Featured in Top 10 Most Downloaded Administrative Law Articles
Administrative Law SSRN Reading List /June 2015 Edition, 07.14.2015
Patrick Smith Posts at TaxProf Blog on D.C. Circuit Z Street opinion and is quoted by Bloomberg BNA Daily Tax Report on the same subject
06.2015
Summary Posted TaxProf Blog of Patrick Smith's Recent Tax Notes Article
TaxProf Blog, 06.10.2015
Ivins Attorney, Patrick Smith, Guest Blogger re: Supreme Court's Direct Marketing Decision
Procedurally Taxing, 06.08.2015
Challenges to Tax Regulations: The APA and the Anti-Injunction Act
Tax Notes, 05.25.2015
IRS Issues Guidance Regarding Credits and Refunds of Tax Withheld from International Payments
Employee Benefits Insider & Corporate Tax Insider, 04.29.2015
IRS Issues Guidance re Tax Withholding on International Payments
04.29.2015
Patrick Smith, A Thank You for Being One of the "Finest Guest Posters"
Procedurally Taxing, 04.06.2015
Ivins Attorney, Patrick Smith, Guest Blogger re: Perez v. Mortgage Bankers Association
Procedurally Taxing - Legal Tax Blog, 03.10.2015
Ivins Attorney, Patrick Smith, Guest Blogger, re: Supreme Court's Direct Marketing Case
Procedurally Taxing - Legal Tax Blog, 03.04.2015
Contingent Purchase Price, Contingent Liabilities and Indemnities in Taxable Acquisitions
Ivins, Phillips & Barker, 11.06.2014
Ivins Attorneys Quoted in Tax Notes Today on Inversion Guidance
Tax Notes Today, 09.24.2014
Interest Netting Between Merging Corporations
Corporate Tax Insider, 07.08.2014
The End of Circular 230 Disclaimers
Employee Benefits Insider, 06.11.2014
Brand X, 3M, and Legal Restrictions On the Payment of Income
Tax Notes, 03.24.2014
District Court Misapplies APA in Florida Bankers Association
Tax Notes, 02.17.2014
BEPS Update: Country-by-Country Reporting
Corporate Tax Insider, 02.05.2014
IPB Attorneys Comment on OECD BEPS-Related Initiative
02.2014
There's a war over R&D tax credits, and companies keep winning. (quoted in blog by Jia Lynn Vang)
Washington Post.com, 01.24.2014
Prototypes and Depreciable Property: An Attempted Distinction
Tax Notes, 01.20.2014
Ivins Files Supreme Court Amicus Brief in Quality Stores Case
12.2013
May Regulations That Violate the APA Be Remanded to the IRS?
Tax Notes, 10.07.2013
Quality Stores and the Status of Revenue Rulings
Tax Notes, 09.09.2013
Note, Incentivizing Conservation: Restructuring the Tax-Preferred Easement Acceptance Process to Maximize Overall Conservation Value
101 Geo. L.J. 1587, 08.2013
Chevron's Conflict with the Administrative Procedure Act
Virginia Tax Review, 06.25.2013
PPL: How to Determine Whether a Foreign Tax Is Creditable
Tax Notes, 03.18.2013
U.S. IRS, Lockheed fight over R&D 'rocket science' tax break (quoted in article by Patrick Temple-West)
Business News, 01.25.2013
The Obama Effect: How the Wealthy are Preparing for the Next Four Years (quoted by Richard C. Wilson)
Family Office Monthly, 11.2012
Application of Proposed CERT Regulations to Acquisitions by Controlled Groups
BNA Tax Management Memorandum, 10.22.2012
LB&I Officially Ends Issue Tiering (quoted in article by J. Coder)
08.17.2012
The APA's Arbitrary and Capricious Standard and IRS Regulations
Tax Notes, 07.16.2012
Waiting for Direction on Refund Penalties (quoted in article by J. Coder)
07.02.2012
What We Didn’t Learn From Home Concrete
Tax Notes, 06.25.2012
DCL Separate Unit Combination and Foreign Use Rules Issues
Tax Notes, 03.12.2012
Standards for Tax Court Review in Equitable Innocent Spouse Cases
Tax Notes, 02.20.2012
FATCA: Information Reporting Rules for US Individuals Holding Specified Foreign Financial Assets
02.17.2012
Expedited Opt-Out Needed for OVDI Participants Who Owe No Tax
Tax Notes, 01.30.2012
The APA’s Reasoned-Explanation Rule and IRS Deficiency Notices
Tax Notes, 01.16.2012
IRS Announces Offshore Voluntary Disclosure Initiative
01.09.2012
Is the Anti-Injunction Act Jurisdictional?
Tax Notes, 11.28.2011
Overcoming Appeals' Bad Rap (quoted in article by J. Coder)
Tax Notes, 09.2011
DC Circuit: 'The IRS Is Not Special'
Tax Notes, 08.30.2011
Omissions From Gross Income and ‘Numerators and Denominators’
Tax Notes, 07.11.2011
Aggregate or Entity Theory of Partnerships for Currency?
Tax Notes International, 06.20.2011
Life After Mayo: Silver Linings
Tax Notes, 06.20.2011
Mannella, State Farm, and the Arbitrary and Capricious Standard
Tax Notes, 04.25.2011
Omissions from Gross Income & Retroactivity
Tax Notes, 04.04.2011
Nature Abhors a Splitter: The FTC Splitter and Indirect FTC Rules
Tax Notes, 02.14.2011
Avoiding Tax Casualties in the Currency War
Tax Notes, 02.07.2011
This article highlights the important transactional foreign currency tax issues that U.S. multinationals face and explains why those issues have taken on added importance in an era of volatile exchange rates. It also describes areas in which policymakers could reduce uncertainty regarding foreign currency tax issues by providing targeted guidance.
Mayo and Chenery: Too Much of a Shift in Rationale?
Tax Notes, 10.25.2010
Gaps in the Seventh Circuit's Reasoning in Lantz
Tax Notes, 09.27.2010
Schedule UTP: Ready or Not, Here It Comes
Tax Management Real Estate Journal, 09.01.2010
Omissions From Gross Income And the Chenery Rule
Tax Notes, 08.16.2010
Contingent Consideration and Contingent Liabilities in Acquisitions
Ivins, Phillips & Barker, 08.2010
VEBA Retiree Medical Reserves -- Two New Tax Reduction Strategies
04.21.2010
Brand X and Omissions From Gross Income
Tax Notes, 02.01.2010
Tax-Free Exchange Treatment for Exchanges of Intangible Property
11.30.2009
Proposed Basis Recovery Regulations
BNA Tax Management Memorandum, 09.14.2009
International Tax Proposals Raise Technical Issues
Tax Notes, 08.03.2009
Accelerated Deductions for Self-Funded Medical Reimbursements – Even Faster than You May Have Believed
06.30.2009
Maximizing the Benefits of Sec. 199 in an Asset Sale
The Tax Advisor, 05.01.2008
Outline of Thoughts on Corporate Distributions
The Tax Magazine, 03.2007
The W-2 Wage Limitation On the §199 Deduction: What W-2 wages and Who gets credit for them?
BNATAX Management, 01.03.2007
Musings on Selected Provisions of the Final §199 Regulations Applicable to Corporate Manufacturers of Tangible Property
Tax Management Inc., 09.04.2006
Accuracy-Related and Fraud Penalties After Enactment of the American Jobs Creation Act of 2004
Federal Bar Association, Section of Taxation Report, Fall 2005
The Domestic Activities Production Deduction: Demystifying the International Tax Aspects
Tax Management International Journal, 08.12.2005
The 199 Domestic Production Activities Deduction: Opportunities, Pitfall, and Ambiguities for Domestic Manufacturers: Part II
Tax Management Memorandum, 07.25.2005
Leading Lawyers
The Legal Times, 07.18.2005
The 199 Domestic Production Activities Deduction: Opportunities, Pitfall, and Ambiguities for Domestic Manufacturers: Part I
Tax Management Memorandum, 07.11.2005
107 Tax Notes 1445 - American Jobs Creation Act of 2004 -- A Selective Analysis
2005 Tax Analysis Tax Notes, 06.13.2005
Tax Bibliographies; Book Reviews, 107 Tax Notes 1445 - American Jobs Creation Act of 2004 -- A Selective Analysis
06.06.2005
Section 165(g)(3) and Section 332 Memorandum
Ivins, Phillips & Barker, 10.08.2004
"Nothing Is Secret Anymore -- U.S. Tax Authorities May Have the Ability to Read a Lot More Internal Memos"
Project Finance NewsWire, 04.2001
87 Tax Notes 1367 - Merging Disregarded Entities
2000 Tax Analysis Tax Notes, 06.05.2000
87 Tax Notes 103 - Mergers & Acquisitions: Questioning Rev. Rul. 96-29's Scope
2000 Tax Analysis Tax Notes, 04.03.2000
"Utilities Keep Tax Benefits in Asset Divestitures"
Project Finance NewsWire, 03.2000
79 Tax Notes 1647 - Another Take on Peracchi
1998 Tax Analysts, 06.22.1998
Hybrid Branches Face Stern Test
9 Int'l Tax Review 19, 03.1998
Current Issues in International Tax Planning for Motion Picture Production and Distribution
Univ. of Southern California Institute on Federal Taxation, 1997
The 6th Edition of B&E: Keeping Pace with the Code, Congress and the Courts
Journal of Taxation, 07.1994
New Guidance Is Needed for the 'Substantially All' Rule as Applied to Acquisitions
Journal of Taxation, 1993
More Problems Complicate the Application of 'Substantially All' to Acquisitions
Journal of Taxation, 1993
IRS Determines Asbestos Removal is Capital Expenditure
Journal of Taxation, 10.1992
Who Incurs Environmental Clean-Up Costs - And Why - May Determine Deductibility
Journal of Taxation, 01.1992
Improved Development of Complex Tax Legislation
American Journal of Tax Policy, 1992
32 Tax Notes 477 - A Revised Roadmap to Section 338
1986 Tax Analysis Tax Notes, 08.04.1986
New Uniform Capitalization and Long-Term Contract Rules
Journal of Taxation, 1986
Advantages of New Tax Court Decision Allow Use of LIFO with Completed Contract Method
Journal of Taxation, 01.1983
An Analysis of the New Proposed Regulations on Use of Published Indices for Dollar-Value
Journal of Taxation, 1981
Insuring that special allocations of partnership income and loss are recognized
Taxation for Lawyers
Making the Most of Special Allocations of Partnership Income and Coping With Risks
Taxation for Lawyers
Financing Foreign Operations Through Domestic Finance Subsidiaries
Virginia Law Review, 1969

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