2 0 0 9

“Jo Ann Engelhardt Interviewed by Jerald David August”, Business Entities, January/February 2009.

“Final Regulations Issued to Tax Return Preparer Penalty Rules: Impact on Estates and Trusts Practitioners”, Jerald David August, Guy B. Maxfield and Jason Grimes. Estate Planning, March 2009.

“Reporting Madoff Investor Losses”, Jerald David August and Ricardo Antaramian. Business Entities, March/April 2009.

“Recent Revisions to the Tax Return Preparer Rules, Circular 230 and Survey of the Attorney-Client Privilege and Work Product Doctrine in Tax Controversies and Litigation.” 67th New York University Annual Institute on Federal Taxation, May 2009.

“Accuracy Related Penalty Under section 6662 Imposed on Joint return Despite Claimed Reliance on Tax Return Preparer. Prudhomme ET US V. Commissioner, Fifth Circuit, July 16, 2009.” Federal Taxation Developments Blog, July 17, 2009, fedtaxlaw.com. [Link]

“‘Primary Purpose Test’ Applied to Work Product of Outside Attorney Conducting Internal Investigation of Behalf of Corporate Client.”  Federal Taxation Developments Blog, July 14, 2009, fedtaxlaw.com. [Link]

“Southern District of New York Bankruptcy Court Issues Final Order Restricting Transfers of Shares in General motors Corp. in Order to Preserve GM’s Tax Attributes.”  Federal Taxation Developments Blog, July 13, 2009, fedtaxlaw.com. [Link]

“Chief Counsel Announces Standard of Review Under Innocent Spouse Equitable Relief Provision.” Federal Taxation Developments Blog, July 6, 2009, fedtaxlaw.com  [Link]

“Seventh Circuit Limits Scope of Federal Tax Practitioner Privilege.”  Federal Taxation Developments Blog, July 4, 2009, fedtaxlaw.com. [Link]

“Bank Secrecy Act and Recent IRS Offshore Disclosure Initiatives”. ALI-ABA, October 2009).

 

2 0 0 8

“Ability of IRS to Discover Tax Accrual and FIN 48 Workpapers”, Jerald David August and Jason Michael Grimes, Business Entities, (Nov./Dec. 2008).

“Expansion of Tax Return Preparer Penalty to Estates and Trusts Practitioners: Recently Issued Proposed Regulations Interpret New Standards”, Jerald David August, Guy B. Maxfield and Jason M. Grimes, Estate Planning, (Nov. 2008).

“Understanding FIN 48, Accounting for Uncertainty in Income Taxes, And Resulting Implications Under Sarbanes-Oxley”, The Practical Tax Lawyer, (Vol. 22, No. 4, Summer 2008).

“Attorney-Client Privilege and Work Product Doctrine in Federal Tax Matters”. Business Entities, (July/Aug. 2008).

“Recent Revisions to the Tax Return Preparer Rules, Circular 230 and Survey of the Attorney-Client Privilege and Work Product Doctrine in Tax Controversies and Litigation”. 66th New York University Annual Institute on Federal Taxation, (May 2008).

“Selected Income Tax Considerations Concerning Choice of Entity for Conducting Business Operations Outside the United States.” Jerald David August and Ricardo A. Antaramian, 66th New York University Annual Institute on Federal Taxation, (May 2008).

“Mergers and Acquisitions Involving S Corporations”, 65th New York University Annual Institute On Federal Taxation, (May 2008)

“Understanding FIN 48: Accounting for Uncertainty in Income Taxes”, Business Entities, (May/June 2008).

“Choice of Entity for Engaging in Business Operations Outside the United States”, Business Entities, (March/April 2008).

 

2 0 0 7

 

“Mergers and Acquisitions of S Corporations – Part 1”, Business Entities, March/April 2007.

“Income Tax Aspects of Forming, Operating, and Exiting FLPs.”, Jerald David August and Casey Scott August, Estate Planning, April 2007.

“Mergers and Acquisitions of S Corporations – Part 2”, Business Entities, May/June 2007.

“Proposed Legislation Would Impose Application of the Rules of Subchapter C for Public Offerings of Private Equity Funds”, Business Entities, July/August 2007.

“Mergers and Acquisitions Involving S Corporations”, Jerald David August and C. Wells Hall III, 66th New York University Annual Institute on Federal Taxation, October/November 2007.

“Recent Revisions to the Tax Return Preparer Rules, Circular 230 and Survey of the Attorney-Client Privilege and Work Product Doctrine in Tax Controversies and Litigation”, New York University Annual Institute on Federal Taxation, October/November 2007.

“Choice of Entity for Engaging in Business Operations Outside the United States”, Jerald David August and Ricardo A. Antaramian, 66th New York University Annual Institute on Federal Taxation, October/November 2007.

“Mergers and Acquisitions Involving S Corporations – Part 3.”, Business Entities, (November/December 2007)

2 0 0 6

“The IRS Continues its Section 2036 Assault on Family Limited Partnerships: Part 2”, Business Entities, (Jan/Feb 2006)

“The Impact of Circular 230 and Tax Shelter Reporting and Disclosure Rules on Privately-Held Companies and Their Tax Advisors” 64th New York University Annual Institute on Federal Taxation, (May 2006)

“The IRS Continues its Section 2036 Assault on Family Limited Partnerships: Part 3”, Business Entities, (May/June 2006)

“Hedge Funds – Structure, Regulations, and Tax Implications: Part 1. Structure and Regulation”, Business Entities, (Jul/Aug. 2006)

“Hedge Funds – Structure, Regulation, and Tax Implications: Part 2. Selected Federal Income Tax Issues”, Business Entities, (Sept/Oct. 2006)

2 0 0 5

“Robert E. Panoff Interviewed by Jerald David August,” Business Entities, (Jan/Feb 2005)

“Impact of Circular 230 Regulations on Estate Practitioners”, Estate Planning Review (June 21, 2005)

“The IRS Continues its Section 2036 Assault on Family Limited Partnerships: Part 1”, Business Entities, (Sept/Oct 2005)

“Carol Kulish Harvey Interviewed by Jerald David August.” Business Entities, (Sept/Oct 2005)

“The Regulations of Tax Professionals by the Internal Revenue Service In a Post-Enron World”, The Practical Tax Lawyer (Fall 2005)

 

2 0 0 4

“Valuation of Interests ‘In Transit’ in Family Limited Partnerships: Part III.” Business Entities (Jan/Feb 2004)

“Reform or Replace Subchapter S: Small Steps Versus Radical Action.” Business Entities (Jul/Aug 2004)

“Avoiding Tax Malpractice In Advising Owners of Closely-Held Business”. 63rd New York University Annual Institute of Federal Taxation, (Oct/Nov. 2004)

2 0 0 3

“Conversions from C to S Status in Light of Pediatric Surgical.” Southern Federal Tax Institute, Atlanta, Georgia (Sept 2003)

“Valuation of Interests In Transit in Family Partnerships: Part I.” Business Entities (Sept/Oct 2003)

“Utilization of Formula Clauses as a Technique to Limit Transfer Taxes.” 62nd New York University Annual Institute on Federal Taxation (Oct/Nov 2003)

“Valuation of Interests In Transit in Family Limited Partnerships: Part II.” Business Entities (Nov/Dec 2003)

 

2 0 0 2

“Jerald David August Interview C. Wells Hall, III.” Business Entities, (Jan/Feb 2002)

“Richard M. Lipton Interviewed by Jerald David August.” Business Entities, (May/June, 2002)

“Guy B. Maxfield Interviewed by Jerald David August.” Business Entities, (Jul/Aug 2002)

“Clarifications made by ESBT Final Regulations Demonstrate the Need for More Statutory Changes,” Journal of Taxation (August 2002)

2 0 0 1

“Jerald David August Interview Donald C. Alexander, Steve Glaze, and William J. Wilkins.” Business Entities, (Mar/Apr 2001)

“Charles H. Egerton Interviewed by Jerald David August.” Business Entities, (Jul/Aug 2001)

“Converting C Corporations to S Corporations: A Review of Important Planning Issues.” Southern Federal Tax Institute, Atlanta, Georgia (October, 2001)

“Prop. Regs. On ESBTs: More Guidance for Family Truss Owning S Stock.” Estate Planning (October, 2001)

“Conversions from C to S to C Status.” 60th New York University Annual Institute on Federal Taxation (Oct/Nov 2001)

2 0 0 0 

“Mergers and Acquisitions Involving S Corporations.” 59th New York University Annual Institute on Federal Taxation (Nov/Dec 2000)

“Jerald David August Interviews F. Brook Voght.” Business Entities (Nov/Dec 2000)

“Jerald David August Interviews Richard A. Shaw.” Business Entities (Sept/Oct 2000)

“Jerald David August Interviews Robert R. Casey.” Business Entities (Jul/Aug 2000)

“Recent Decisions Frustrate Service’s Efforts to Challenge FLPs.” Estate Planning,
(November, 2000)

“Jerald David August Interviews Richard A. Shaw.” Business Entities, (Sept/Oct 2000)

“Jerald David August Interviews Robert R. Casey.” Business Entities, (Jul/Aug 2000)

“Final Hubert Regs. Fix Boundaries for Deducting Administration Expenses.”, Estate Planning (June, 2000)

“Recent Decisions Impact Redemption of Stock Incident to Divorce: Must Read-ing for Tax Practitioners.” Business Entities (Mar/Apr, 2000)