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All Attorneys Fred Feingold

• Commentary: Are Tax-Exempt Investors Really Tax Exempt?, Pensions & Investments (co-authored with Edward H. Klees)

  08/12/2019
• Insight: IRS Regulations Surprisingly Permit Certain Partners to Avoid GILTI, Bloomberg BNA Daily Tax Report (co-authored with Mark Berg)

  07/30/2019
• Insight: IRS Regulations Surprisingly Permit Certain Partners to Avoid GILTI, Bloomberg BNA Daily Tax Report (co-authored with Fred Feingold)

  07/30/2019
• Hot Potato: Tax-Exempt Investors’ Liability for Other Partners’ Taxes After the 2015 Bipartisan Budget Act, panelist for webinar presented by Hirschler P.C.

  05/07/2019
• Tax Primer: Implications of IP Transactions, presentation at the International Trademark Association’s 2019 March Conference: The Business of Brands

  03/28/2019
• Insight: The Proposed Federal Wealth Tax Would Be Unconstitutional, Bloomberg BNA Daily Tax Report

  02/25/2019
• Institutional Investors and the 2017 Tax Act, panelist for webinar presented by the American Bar Association Business Law Section, Institutional Investors Committee

  07/24/2018
• The Deemed Repatriation Tax — A Bridge Too Far?, 158 Tax Notes 1345 (co-authored with Mark E. Berg)

  03/05/2018
• The Deemed Repatriation Tax — A Bridge Too Far?, 158 Tax Notes 1345 (co-authored with Fred Feingold)

  03/05/2018
• The Proposed Regulations Shine a Light on the Mysterious Nature of the Section 2801 Tax and Its Intentions

  03/16/2016
• Attention Must Be Paid When Credit Is Due, Tax Notes, Vol. 150 No. 2

  01/11/2016
• Tax Planning in the 'Economic Substance' Era, 149 Tax Notes 65

  10/05/2015
• Tax Department Reads Taxpayer Residency Victory Narrowly, New York Law Journal

  08/11/2014
• New York’s High Court Eases Residency Trap, 72 State Tax Notes 335

  05/12/2014
• Learning from the Masters — What Sergio Garcia and Retief Goosen can teach us about the tax treatment of endorsement contracts, International Tax Institute

  05/14/2013
• Determining Which Taxes Are Prohibited Direct Taxes After NFIB, 138 Tax Notes 205

  01/14/2013
• Implications of FATCA and Intergovernmental FATCA Agreements, Centro di Studi Bancari (Lugano)

  11/29/2012
• Wealth Tax Proposal Unconstitutional, Practitioner Says, 136 Tax Notes 125

  07/02/2012
• Judicial Deference to Tax (and Other) Regulations: The Supreme Court Speaks Again in U.S. v. Home Concrete, Co-Chair, American Law Institute-American Bar Association teleseminar

  06/05/2012
• Bar the Exit (Tax)! Section 877A, the Constitutional Prohibition Against Unapportioned Direct Taxes and the Realization Requirement, 65 Tax Lawyer 181

  01/01/2012
• Tax lawyers on the game and on stage: Tax planning for athletes, sports leagues, entertainers, et al., IBA (Dubai)

  10/31/2011
• Section 877A, A Technical Journey Through An Imaginary Construct, 281 Tax Review

  01/10/2011
• Further Guidance Needed on Who Must Report Foreign Accounts, Tax Notes

  05/25/2009
• Judicial Deference to Tax Regulations: A Reconsideration in Light of National Cable, Swallows Holding and Other Developments, 61 Tax Lawyer 481

  01/01/2008
• Attorney Suggests Changes to Proposed Regs on Practice Standards, Return Preparer Penalties, 2007 Tax Notes Today 213-19

  11/02/2007
• Selected Issues Regarding S Corporations With Foreign Operations, outline and panel discussion (moderator) before the American Bar Association Section of Taxation S Corporations Committee, Vancouver, British Columbia

  09/28/2007
• Brief Outline of U.S. Tax Considerations Relevant to Artists, Entertainers and Athletes with a Particular Emphasis on Their Personal Appearance Income (IBA, London)

  03/06/2006
• Practitioners’ Reaction Indicates Need for Clearer Circular 230 Rules, 108 Tax Notes 245

  07/11/2005
• The Attempted Extra Statutory Application Of “Withholding” Under Sections 1441 And 1446 In Respect Of Income Of Certain U.S. Persons, The Mysterious Nature Of The Section 1446 Withholding Tax Liability And Certifiable Hysteria Precluding Reliance On Payee's Certificates And Other Anamolies

  06/13/2005
• The Complex Domestic Trust, a Potential Vehicle for Reducing the Tax on U.S. Source Non-Effectively Connected Dividend Income of Non-U.S. Persons and Capital Gains of Certain Corporations?

  09/01/2003
• Treaty Entitlements through the Looking Glass: Changing the Meanings but Not the Words, Tax Review

  04/01/2001
• Tax Planning and Pitfalls for International Entertainers Case Study: U.S. Perspective, Section I — Source Country — Non Treaty Situation, and Outline of Comments to the General Structure of the Contract, IBA, Barcelona

  09/01/1999
• The Treatment of Partnerships, LLCs and S Corporations Under Income Tax Treaties, 1 Business Entities No. 4, at 20

  07/01/1999
• Article 17 — the Artiste Clause — Time for Reconsideration, Tax Club

  01/01/1999
• Tax Court Refuses to Attribute a Shareholder's Intangible Assets to the Corporation, 10 Journal of S Corporation Taxation 146

  09/01/1998
• Source of Gain or Loss on Sales of S Corporation Stock, 9 Journal of S Corporation Taxation 179

  09/01/1997
• Payments to Non-U.S. Pass-Through Entities, Treaty Benefits and the New Proposed Withholding Regulations, 8 Journal of S Corporation Taxation 369

  03/01/1997
• Checking the Box: New Proposed Regulations Would Simplify Entity Classification and Afford Planning Opportunities, 8 Journal of S Corporation Taxation 195

  01/01/1997
• Brown Group Redux: The Eighth Circuit Speaks, 8 Journal of S Corporation Taxation 161

  09/01/1996
• Equity Investments by Pension Funds: The ERISA Plan Assets Rule, 8 Journal of S Corporation Taxation 69

  06/01/1996
• Corporate Distributions of Partnership Interests: The Pope & Talbot Case, 7 Journal of S Corporation Taxation 330

  01/01/1996
• Final Anti-Abuse Regulations Address the Aggregate/Entity Issue, 7 Journal of S Corporation Taxation 168

  09/01/1995
• Brown Group Revisited, 7 Journal of S Corporation Taxation 71

  06/01/1995
• How Tax Treaties Affect Use of LLCs in International Transactions, 2 Journal of Limited Liability Companies 20

  06/01/1995
• Proposed Expatriation Rules

  04/01/1995
• Recasting Havoc: The Impact of the Proposed Partnership Anti-Abuse Rules on S Corporations as Partners, 6 Journal of S Corporation Taxation 317

  03/01/1995
• The Continuing Aggregate/Entity Saga: Brown Group is Right, 6 Journal of S Corporation Taxation 271

  01/01/1995
• Entitlement to Treaty Benefits: a Comparison of the Dutch and German Solutions

  09/13/1994
• Aggregate/Entity Concepts for S Corporations: Recent Decisions a Mixed Bag, 6 Journal of S Corporation Taxation 185

  09/01/1994
• Impact of the New U.S.-Netherlands Treaty on REIT Investments, 6 Journal of S Corporation Taxation 80

  06/01/1994

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