“Commissioner Issues Temporary and Proposed Regulations on Reporting Foreign Financial Assets For Individuals and Domestic Entities.” Federal Taxation Developments Blog, January 1, 2012, foxrothschild.com. [Link]

“President Obama Announces Corporate Income Tax Reform Proposal: Rate Reduction.” Federal Taxation Developments Blog, February 2, 2012, foxrothschild.com. [Link]

“Treasury Issues Final, Temporary and Proposed Regulations on Cost Sharing Agreements”.Federal Taxation Developments Blog, February 2, 2012, foxrothschild.com. [Link]

“Treasury Issues Proposed Regulations on FATCA: Joint Statement Issued with 5 European Nations Outlining an Alternative Approach.” Federal Taxation Developments Blog, February 15, 2012, foxrothschild.com. [Link]

“Facebook Founder, Mark Zuckerberg, Expected to Realize $6 Billion in Gross Income On Exercise of Nonqualified Stock Options in Facebook’s Initial IPO.” Federal Taxation Developments Blog, February 15, 2012, foxrothschild.com. [Link]

“President Obama Announces Corporate Income Tax Reform Proposal: Rate Reduction”. Federal Taxation Developments Blog, February 22, 2012, foxrothschild.com. [Link]

“United States Department of Justice Files Indictments Against Switzerland’s Oldest Private Bank And Employees of Other Swiss Banks.” Federal Taxation Developments Blog, March 20, 2012, foxrothschild.com. [Link]

“French Parliament Recently Enacts Legislation for Tax and Disclosure Obligations on Trusts: France’s Version of FATCA.” Federal Taxation Developments Blog, March 20, 2012, foxrothschild.com. [Link]

“New Regulations Under Section 108(e)(8); Creditor’s Contribution of Debt to Debtor Partnership In Exchange For Equity Interest.” Federal Taxation Developments Blog, March 20, 2012, foxrothschild.com. [Link]

“Service and Treasury Still Waiver on the Final Content of Additional Regulations To Be Issued Under Section 7874 On When Stock of a Foreign Corporation is Properly Disregarded For Whether An Inversion Transaction Has Occurred.” Federal Taxation Developments Blog, April 1, 2012, foxrothschild.com. [Link]

“Commissioner Prevails in Imposing Deficiency With Respect to At-Risk Recapture in Roy Zeluck, TC Memo 2012-98.” Federal Taxation Developments Blog, April 8, 2012, foxrothschild.com. [Link]

“Treasury and Internal Revenue Service Issue New Temporary Regulations on “All Cash” Type D Reorganizations.” Federal Taxation Developments Blog, April 11, 2012, foxrothschild.com. [Link]

“Third Circuit Reverses Tax Court And Holds Taxpayers Received Tax-Exempt Interest on Deferred Payments From the Pennsylvania Department of Transportation Negotiated as Part of an Out-of-Court Settlement.” Federal Taxation Developments Blog, April 13, 2012, foxrothschild.com. [Link]

“Treasury and Internal Revenue Service Issue Final Regulations on the Reporting Requirements for Interests on Deposits Maintained at U.S. Offices of Financial Institutions Paid to Nonresident Aliens.” Federal Taxation Developments Blog, April 27, 2012, foxrothschild.com. [Link]

“Tax Notes Reports on Comments Made by the Director of the IRS Whistleblower Office at a OffshoreAlert Conference Recently Held in Miami Beach.” Federal Taxation Developments Blog, May 16, 2012, foxrothschild.com. [Link]

“Facebook Co-Founder Eduardo Saverin Criticized for Renouncing U.S. Citizenship Presumably Generated by Tax Savings.” Federal Taxation Developments Blog, May 21, 2012, foxrothschild.com. [Link]

“Recent IRS Hearings on FATCA Implementation Draws Criticism From the Banking and Financial Services Sectors.” Federal Taxation Developments Blog, May 21, 2012, foxrothschild.com. [Link]

“Tax Court Memorandum Decision Denies Charitable Deduction for Highly Valued Real Estate in Joseph Mohamed, Sr., TC Memo 2012-152.” Federal Taxation Developments Blog, June 4, 2012, foxrothschild.com. [Link]

“Administrative and Judicial Review of Tax Controversies in Canada.” Federal Taxation Developments Blog, June 17, 2012, foxrothschild.com. [Link]

“Service Issues New Revenue Ruling on Dividends and Dividend Equivalent Grants That Can Be Treated As Performance-Based Compensation for Purposes of Section 162(m).” Federal Taxation Developments Blog, June 22, 2012, foxrothschild.com. [Link]

“UK Telecommunications Company Vodafone Recently Receives Favorable Ruling from Supreme Court of India.”>Federal Taxation Developments Blog, June 26, 2012, foxrothschild.com. [Link]

“Chief Counsel’s Advisory 201212008 Holds Green Card Holders Working for Foreign Government In the United States Were Not Exempt From U.S. Tax.” Federal Taxation Developments Blog, July 1, 2012, foxrothschild.com. [Link]

“Chief Counsel’s Advisory 201212008 Holds Green Card Holders Working for Foreign Government In “Eighth Circuit Court of Appeals Gives Service A Major Victory To Recharacterize Distributions from an S Corporation to Its Shareholder(s) as Wages for FICA Purposes.” Federal Taxation Developments Blog, July 8, 2012, foxrothschild.com. [Link]

“Federal District Court for Arizona Rejects Taxpayers’ Calculation of Stock Basis Attributable to Sale of Stock From Various Insurance Companies That Had Previously Converted from a Mutual Based to a Stock Based Company: Dorrance v. United States, 110 AFTR.” Federal Taxation Developments Blog, July 13, 2012, foxrothschild.com. [Link]

“Manchester United IPO Looks Very Much Like a Purposely Designed Inversion Transaction Described Under Section 7874 To End Run Section 367(d).”  Federal Taxation Developments Blog, August 27, 2012, foxrothschild.com. [Link]

“Service Issues Notice On Outbound Asset Reorganizations: Notice 2012-39, 2012-31 IRB 95.” Federal Taxation Developments Blog, August 29, 2012, foxrothschild.com. [Link]

“IRS Proposes Revocation of the Covered Opinion Standards in Circular 230 As Part of a Package of Proposed Regulations Covering the Ethics Rules Governing Individuals Who Practice Before the IRS.” Federal Taxation Developments Blog, September 26, 2012, foxrothschild.com. [Link]

“Recent Amendments to Tax Court Rules of Practice and Procedure on Work Product and Discoverability of Expert Witness Reports and Communications to Petitioner’s Counsel.” Federal Taxation Developments Blog, October 12, 2012, foxrothschild.com. [Link]

“Service Issues First Notices on Hurricane Sandy; Casualty Losses, Government Assistance Payments.” Federal Taxation Developments Blog, November 4, 2012, foxrothschild.com. [Link]

“FATCA Timelines Announced by IRS for Withholding Agents, Foreign Financial Institutions in Announcement 2012-42; 2012-47 IRB.” Federal Taxation Developments Blog, November 4, 2012, foxrothschild.com. [Link]

“Transfer Pricing Decision Recently Rendered by the Supreme Court of Canada in GlaxoSmithKline, Inc. v. The Queen, 2012 SCC 52.” Federal Taxation Developments Blog, November 4, 2012, foxrothschild.com. [Link]

“Capital Gains and Dividend Income Tax Rates Scheduled to Increase in 2013: Added Impact of New Medicare Contribution Tax.” Federal Taxation Developments Blog, November 4, 2012, foxrothschild.com. [Link]

“Treasury Department Announces Further Actions to Implement the Foreign Account Tax Compliance Act (FATCA).” Federal Taxation Developments Blog, November 19, 2012, foxrothschild.com. [Link]

“Department of Justice, Civil Tax Division, Awarded Summary Judgment to Collect Civil Penalties Against Taxpayer For Willfully Failing to FBAR Reports for Two Years.” Federal Taxation Developments Blog, November 19, 2012, foxrothschild.com. [Link]

Financial Accounting Standards Board Continues to Review Application of FIN 48 (ASC-70) to Private Companies.” Federal Taxation Developments Blog, November 25, 2012, foxrothschild.com. [Link]

“United States Enters Into Third Intergovernmental Agreement Under FATCA: Agreement Signed with Mexico.” Federal Taxation Developments Blog, December 6, 2012, foxrothschild.com. [Link]

“U.S. and Multi-national Companies Engaged in Canadian Business Operations Through Controlled Canadian Subsidiaries Need to Stand On Guard for Possible Legislation on Interest Stripping and Other Rules.” Federal Taxation Developments Blog, December 6, 2012, foxrothschild.com. [Link]

“Service Issues Final Regulations (T.D. 9606) on Sales of Stock Between Controlled Corporations: Redesigning the Anti-Avoidance Regulation in Section 304.” Federal Taxation Developments Blog, December 30, 2012, foxrothschild.com. [Link]