“IRS Releases Private Letter Ruling on Dividend Impacts of a “Foreign Sandwich.” Federal Taxation Development Blog, January 20, 2010, foxrothschild.com 

“National Office of IRS Issues Private Letter Ruling on the Isolated Redemption Exception to Section 302(B)(1). PLR 201002022 (1/15/2010) Federal Taxation Development Blog, January 20, 2010, foxrothschild.com

“Court of Claims Strikes Down Wells Fargo’s Silos Tax Shelters.” Federal Taxation Development Blog, January 20, 2010, foxrothschild.com

“The Discovery Status of Tax Accrual Workpapers After TEXTRON”, Jerald David August and Jason M. Grimes, Business Entities, (Jan/Feb 2010).

“The One Year (More of Less) Repeal of the Federal Estate and Generations Skipping Transfer Taxes: What Hath Congress Wrought on Us Poor Estate Planners and Our Clients”, In Depth Analysis of Impact on Estate & Small Business Planning, ALI-ABA, (February 16, 2010).

“The One Year (More of Less) Repeal of the Federal Estate and Generations Skipping Transfer Taxes: What Hath Congress Wrought on Us Poor Estate Planners and Our Clients”, In Depth Analysis of Impact on Estate & Small Business Planning, ALI-ABA, (February 16, 2010).

“The Modified Carryover Basis Regime”, In Depth Analysis of Impact on Estate & Small Business Planning, ALI-ABA, (February 16, 2010)

“First Circuit Court of Appeals Holds Tax Accural Workpapers and Related Documents Used to Prepare Financial Statements are Not Work Product Under the Hickman V. Taylor Doctrine” Federal Taxation Development Blog, February 28, 2010, foxrothschild.com

“Special Deferral Rule for Reporting Cancellation of Indebtedness Income Under New Section 108 (I) for 2009 and 2010”. Federal Taxation Development Blog, April 23, 2010, foxrithschild.com

“Canadian Tax Court Rules Delaware LLC is U.S. Resident for Treaty Purposes in TD Securities (USA) LLC V. Her Majesty the Queen; 2008-2314(IT)G [2010 TCC 186]“. Federal Taxation Development Blog, April 20, 2010, foxrothschild.com

“Who Needs to Fight Textron-Type Litigations Summons Cases for Tax Accural Workpaper and FIN 48 Workpaper the Government Effectively Askes?Just Make Disclosure of Uncertain Tax Positions Part of the Return. IRS Announcement 2010-9, 2010-7 IRB 408. 2010-7”. Federal Taxation Development Blog, April 17, 2010, foxrothschild.com.

“Technical Advice Memorandum Holds Theat Premiums Fail to Controlled Foreigh Corporation Insurance Company Constituted Subpart F Income“. Federal Taxation Development Blog, April 17, 2010, foxrothschild.com.

“Second Circuit Court of Appeals Reverses Tax Court and Permits Expensing of Royalty Payments Incurred on Sales of Inventory”. Federal Taxation Development Blog, April 9, 2010, foxrothschild.com.

“Selected Income Tax Considerations Concerning Choice of Entity for Conducting Business Operations Outside the United States”, 68th New York University Annual Institute on Federal Taxation, (May 2010).

“Memorandum Decision by Judge Wells Rejects Presence of Payment of Control Premium in Determining the Value of a Partnership Interest for Purposes of the Built-In Gains Tax Under Section 1374; Ringgold Telephone Company V. Commissioner, TC Memo 2010-103”. Federal Taxation Development Blog, May 12, 2010, foxrothschild.com.

“Codification if Economic Substance Dovtrine Under the Health Care and Education Reconciliation Act of 2010 (“Hire Act”), P.L. No. 111-152″, Federal Taxation Development Blog, May 13, 2010, foxrothschild.com.

“IRS Provides Guidance for Small Business That Qualify for the New Healthcare Tax Credit”. Federal Taxation Development Blog, May 20, 2010, foxrothschild.com.

“New Market Tax Credits: Attracting New Capital for Real Estate Projects in Distressed Communities” Federal Taxation Development Blog, May 20, 2010, foxrothschild.com.

“Shrink-Wrapped Software: Royalty Versus Business Income Under the Domestic Tax Law of India”. Federal Taxation Development Blog, May 20, 2010, foxrothschild.com.

“Tax Court Holds Foreign Parent’s Fee for Guarantying U.S. Subsidiary’s Debt is Foreign Source Service Income”. Federal Taxation Development Blog, May 29, 2010, foxrothschild.com

“Gross Up Payments Made With Respect to Golden Parachute Payments Under Section 280G”. Federal Taxation Development Blog, May 30, 2010, foxrothschild.com.

“IRS Notice 2010-41, 2010-22 IRB 715: Regulations Will be Issued That Will Classify Some Domestic Partnerships as Foreign Partnerships for Applying the Controlled Foreign Corporations Rules”. Federal Taxation Development Blog, June 6, 2010, foxrothschild.com.

“Treasury Issues proposed Regulation to Section 1001 pertaining to Debt Modification Rules”. Federal Taxation Development Blog, June 6, 2010, foxrothschild.com.

“The Permanent Establishment of a Foreign Person in the United States Under U.S. Income Tax Convention”. Federal Taxation Development Blog, June 9, 2010, foxrothschild.com.

“Commissioner of the Internal Revenue Service Announces Joint Audits for Persons With International Tax Profiles; Update on UBS Initiative.”  Federal Taxation Development Blog, June 9, 2010, foxrothschild.com.

“Service Issues Final Regulations Under the Anti-Abuse Rule to Section 704(C).” Federal Taxation Development Blog, June 9, 2010, foxrothschild.com.

“Outbound Transfers of Appreciated Property by U.S. Persons to Foreign Corporations: Avoiding the Pitfalls”. Federal Taxation Development Blog, June 9, 2010, foxrothschild.com.

“USB Update: Swiss Parliament Gives Final Approval to Release 4,450 Bank Deposit Information of U.S. Persons”. Federal Taxation Development Blog, June 22, 2010, foxrothschild.com.

“Service Rules That Cross-Border Debt Cancellation Between Related Parties Did Not Result in Cancellation of Indebtedness Income.” Federal Taxation Development Blog, June 22, 2010, foxrothschild.com.

“Renewed Emphasis by Internal Revenue Seervice in Auditing International Concerns and Policing Transfer Pricing Requirements”. Federal Taxation Development Blog, June 22, 2010, foxrothschild.com.

“Federal Imposition of Accuracy-Related Penalties on Son of Boss Tax Shelters in Stobie Creek Investments”. Federal Taxation Development Blog, June 30, 2010, foxrothschild.com.

“Ways and Means Chair Speaks on Carried Interest Compromise”. Federal Taxation Development Blog, July 1, 2010, foxrothschild.com.

“Tax Court’s Decision in Xilinx Affrimed by the Ninth Circuit Court of Appeals”. Federal Taxation Development Blog, July 6, 2010, foxrothschild.com.

“Tax Court, in a Fully Reviewed Opinion, Holds That 90% Stock Loan Tax Scheme Program Was a Disguised Sale Lizzie W. Calloway, Et Vir. V. Commissioner, 135 T.C. No. 3, July 8, 2010”. Federal Taxation Development Blog, July 8, 2010, foxrothschild.com.

“Tax Court Rules on Jurisdiction to Hear Denial of Whistleblower Claim Under Section 7623 in William P. Cooper, III V. Comm’r, 135 T.C. No. 4, July 8, 2010.” Federal Taxation Development Blog, July 8, 2010, foxrothschild.com.

“Lebron James, The Miami Heat, and Section 409A of the Internal Revenue Code”. Federal Taxation Development Blog, July 15, 2010, foxrothschild.com.

“Service Issues Guidance to Examination Division on Deferred Gain Recognition Agreements Involving Outbound Transfers of Stocks and Securities to Foreign Corporations”. Federal Taxation Development Blog, July 30, 2010, foxrothschild.com.

AUGUST 2010

“The Organisation for Economic Co-Operation and Development (“OECD”) Issues Discussion Draft on Athletes and Entertainers Under OECD Model Treaty”.  Federal Taxation Development Blog, August 3, 2010, foxrothschild.com.

“IRS Issues Action on Decision and Nonacquiescence to the Fifth Circuit Court of Appeals Recent Decision in Tidewater, Inc. and Subsidiaries”. Federal Taxation Development Blog, August 3, 2010, foxrothschild.com.

“Review of Incorporation of a Partnership: Rev. Rul. 84-111, 1984-2 C.B. 88”. Federal Taxation Development Blog, August 9, 2010, foxrothschild.com.

“Service Issues Temporary Regulations Under Section 108(I), Election to Defer Cancellation of Indebtedness Income for Corporations and Partnerships”.  Federal Taxation Development Blog, August 16, 2010, foxrothschild.com.

“Update on Offshore Bank Secrecy Directives by The United States and The Internal revenue Service: “Mining the UBS Lake” for U.S. Tax Evaders”. Federal Taxation Development Blog, August 16, 2010, foxrothschild.com.

“Service Recently Issues Favorable Continuity of Business Interest Private Letter Ruling on R&D Activities”. Federal Taxation Development Blog, August 17, 2010, foxrothschild.com.

“Anticipated Up-Tick in Merger and Acquisition Activity; Don’t Forget About the Change of Control Provision Section 280G”. Federal Taxation Development Blog, August 23, 2010, foxrothschild.com.

“Service Issues Notice 2010-58 in Provisind Guidance Under Longer Net Operationg Loss Carryback Periods Recently Granted by Congress”. Federal Taxation Development Blog, August 26, 2010, foxrothschild.com.

“Service Issues Preliminary Guidance on Expanding Information Reporting Requirements for Foreign Financial Institutions and U.S. Accounts on Withholding, reporting and Other Requirements for Certain Payments Made to Foreign Entities in Notice 2010-60; 2010.”  Federal Taxation Development Blog, August 26, 2010, foxrothschild.com.

“Special Deferral of Cancellation of Indebtedness Income Under Section 108(I) Continues Through This Year.” Federal Taxation Development Blog, August 30, 2010, foxrothschild.com.

“National Office Issues Favorable Ruling to U.S. Conolidated Group having Foreign Parent to Mixed Use of LIFO and Non-LIFO Financials Without Violating the LIFO Conformity Rule in PLR 2101034004 (8/27/2010).” Federal Taxation Development Blog, September 4, 2010, foxrothschild.com.

“IRS Issues Notice 2010-62 Stating How it Will Apply the Economic Substance Clarification Rule in Section 7701 (O)”.  Federal Taxation Development Blog, September 15, 2010, foxrothschild.com.

“Service Issues Landmark Proposed Regulations on Series Limited Liability Companies.” Federal Taxation Development Blog, September 27, 2010, foxrothschild.com.

“The Codification of the Economic Substance Doctrine – Part I”, Business Entities, (Sept./Oct. 2010).

“Foreign Account Tax Compliance Act (FATCA) and its Impact on Exempt Organizations”. Federal Taxation Development Blog, October 5, 2010, foxrothschild.com.

“Ways and Means Committee Leader, Sander Levin (D-MICH.) Predicts transfer Pricing Legislation During “Lame Duck” Session of Congress This Year.” Federal Taxation Development Blog, October 8, 2010, foxrothschild.com.

“IRS Issues Announcements 2010-75 and 2010-76 IRB, on Changes to Draft Schedule for Reporting of Uncertain Tax Positions on Tax Returns.”  Federal Taxation Development Blog, October 22, 2010, foxrothschild.com.

“Mutual Fund’s Income form a Controlled Foreign Corporation Constitutes Qualifiying Income for Purposes of Section 851(B)(2): Private Letter Ruling 201037014 (09/17/2010)”. Federal Taxation Development Blog, October 22, 2010, foxrothschild.com.

“Department of Justice Dismisses Criminal Charges Against UBS.”  Federal Taxation Development Blog, October 22, 2010, foxrothschild.com.

“Structuring Compensation Arrangements for U.S. Individuals Working Overseas.”   Federal Taxation Development Blog, November 11, 2010, foxrothschild.com.

“Foreign Tax Credit Provisions Revised by Recent Legislation.”  Federal Taxation Development Blog, November 11, 2010, foxrothschild.com.

“Tax Court Upholds regulations Defining “Underpayment” in Feller V. Commissioner, 135 T.C. No. 25 (11/8/2010).” Federal Taxation Development Blog, November 28, 2010, foxrothschild.com.

“The Codification of the Economic Substance Doctrine – Part II”, Business Entities, (Nov./Dec. 2010).

“New 2010 Tax Relief Act Extends Subpart F Exception for Active Financing Income Extended Through Tax Years Beginning Before 2012”. Federal Taxation Development Blog, December 18, 2010, foxrothschild.com.

“New 2010 Tax Relief Act Addresses and Extends rules regarding Payments between Related Controlled Foreign Corporations Under the Foreign Personal holding Company Rules.” Federal Taxation Development Blog, December 18, 2010, foxrothschild.com.

“New Tax Relief Act of 2010 Extends 15% Withholding on United States Real Property Gains Pass Through to Foreign Persons by U.S. Partnerships, Trusts or Estates.”  Federal Taxation Development Blog, December 19, 2010, foxrothschild.com.

“New Tax Relief Act of 2010 Repeals Gain Recognition for Certain Transfers of Property to Nonresident Aliens and Grantor Trusts.”  Federal Taxation Development Blog, December 24, 2010, foxrothschild.com.

“Service Issues New Procedure on Adequate Disclosure for Accuracy Related Penalty Purposes.” Federal Taxation Development Blog, December 24, 2010, foxrothschild.com.