“Treasury Issues Proposed Regulations Requiring U.S. Banks to File Annual Information Statements With Respect to Payments of Interest Income to Non-resident Alien Individuals.” Federal Taxation Developments Blog, January 7, 2011, foxrothschild.com. [Link]

“Seventh Circuit Court of Appeals, in Beard, 107 AFTR 2d 2011 (1/26/2011) Reverses Tax Court By Finding That Overstatement of Basis From Tax Shelter Investment May Constitute an Omission From Gross Income.” Federal Taxation Developments Blog, January 31, 2011, foxrothschild.com. [Link]

“Canadian Investment in U.S. Based Private Equity Funds: Preference for the U.S. Limited Liability Company.” Federal Taxation Developments Blog, February 4, 2011, foxrothschild.com. [Link]

“Reasonable Cause to Avoid Accuracy Related Penalty Based on Advice of Legal Counsel Rejected by Tax Court in Canal Corp. and Subsidiaries et al v. Commissioner, 135 T.C. No.9 (2010).” Federal Taxation Developments Blog, February 13, 2011, foxrothschild.com. [Link]

Second Circuit Affirms District Court’s Decision Rejecting Claim for Refund Based on Claimed Overvaluation of Employee Stock.” Federal Taxation Developments Blog, February 17, 2011, foxrothschild.com. [Link]

“New Chief Counsel Advisory Rules that Sale of Software Products By a Controlled Foreign Corporation to End-User Customers in the U.S. Did Not Constitute an Investment in the U.S.” Federal Taxation Developments Blog, February 22, 2011, foxrothschild.com. [Link]

“Inside Section 897: Investments and Dispositions of U.S. Real Property Interests by Nonresidents”, Business Entities (Nov/Dec 2011).

“The Uncertain State of Uncertain Tax Positions”, Business Entities, (May/June 2011).

“Federal Income Taxation of Single Member Entities: ‘Tax Nothings’”, Jerald David August, Richard A. Shaw and Jordan David August, 69th New York University Annual Institute on Federal Taxation, (May 2011).

“Tax Implications of U.S. Persons Engaged in Business Operations in Brazil”, Jerald David August and Ricardo A. Antaramian, The Practical Tax Lawyer, (Spring 2011).

“Federal Income Tax Compliance: Important Developments”, Jerald David August, Ian M. Comisky & A. Trevor Ackerman, ALI-ABA, (March 2011).

“Mandatory Disclosure of Uncertain Tax Positions On Income Tax Returns Filed by Corporate Taxpayers: The IRS’s New Weapon”, The Practical Tax Lawyer, (Winter 2011).