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All Attorneys Fred Feingold

• The RRA '93 Relief for Workouts of Troubled Real Property Debt: Impact on S Corporations and Partnerships, 5 Journal of S Corporation Taxation 349

  03/01/1994
• International Investments Through S Corporations, outline and presentation to National Institute of Tax Professionals, New York, New York

  11/03/1993
• Certain Tax Consideration relating to Acquisitions of U.S. Investments by Non-U.S. Persons, N.Y. University, 52nd Institute of Federal Taxation

  11/01/1993
• Certain Tax Issues Relating to International Commercial Agreements, PLI

  10/01/1993
• The Application of the Built-in Gains Tax to S Corporations as Partners, 5 Journal of S Corporation Taxation 174

  09/01/1993
• Multistate Planning With S Corporations, outline and panel discussion before the American Bar Association Section of Taxation's S Corporations Committee, New York, New York

  08/06/1993
• Planning for S Corporations With New York Operations or Shareholders: Part II, 5 Journal of S Corporation Taxation 93

  06/01/1993
• Federal Income Tax Treatment of Intangibles, outline and presentation to New Jersey State Bar Association Tax Section, Newark, New Jersey

  03/17/1993
• Planning for S Corporations With New York Operations or Shareholders: Part I, 4 Journal of S Corporation Taxation 379

  03/01/1993
• Cooperatives and their Patrons: The Status of Interest on Working Capital, 4 Journal of S Corporation Taxation 169

  09/01/1992
• Passive Income Problems of an "S" Corporation, New York Law Journal, at 5

  08/13/1992
• Resolving the Class Struggle: New Proposed One-Class-of-Stock Regulations, 3 Journal of S Corporation Taxation 267

  06/01/1992
• The Impact on S Corporations and Their Shareholders of New York and Other Local Tax Laws, outline and New York State Bar Association continuing legal education presentation, New York, New York

  04/30/1992
• Both a Borrower and a Lender Be: The New "Self-Charged" Interest Rules, 3 Journal of S Corporation Taxation 194

  01/01/1992
• New York Tax Rules May Reduce Corporate Loss Carryovers, New York Law Journal at 5 (co-authored with Joseph Lipari)

  12/12/1991
• The 'Kinder and Gentler' Proposed Single-Class-of-Stock Regulations, 53 Tax Notes 713 (co-authored with Jerald D. August, Richard D. Blau and Bruce N. Lemons)

  11/11/1991
• New Proposed Tax Rules on 'S Corporation' Eligibility, New York Law Journal at 5

  10/03/1991
• Venturing Beyond the Straight-Debt Safe Harbor: Treasury Founders on the Legislative History, Journal of Taxation of S Corporations at 10

  06/01/1991
• The Passive Activity Loss Limitation: Special Considerations for S Corporation Shareholders, outline and panel discussion before the American Bar Association Section of Taxations S Corporations Committee, Washington, DC

  05/17/1991
• Using Split-Dollar Life Insurance Arrangements for Employees and Shareholders, 2 Journal of S Corporation Taxation 171 (co-authored with William C. Schanlaber)

  01/01/1991
• Limitation on Benefits, an Overview, Tax Review

  12/01/1990
• Use of S Corporations in Split-Dollar Insurance Arrangements and Advanced Estate Planning Techniques, outline and panel discussion before the American Bar Association Section of Taxation's S Corporations Committee, Washington, DC

  05/04/1990
• Treaty Provisions Found Not to Prohibit Excess Interest Tax, 37 Canadian Tax Journal 1092

  07/01/1989
• Whither the Branches?, 44 Tax Law Review No.2, 205 (co-authored with Mark E. Berg)

  01/01/1989
• Whither the Branches?, 44 Tax Law Review 205 (branch profits tax) (co-authored with Fred Feingold)

  01/01/1989
• An Analysis of the Temporary Regulations Under FIRPTA, Part I, 69 J. Taxation, No. 4, 262 (co-authored with Peter A. Glicklich)

  01/02/1988
• An Analysis of the Temporary Regulations Under FIRPTA, Part II, 69 J. Taxation, No. 5, 348 (co-authored with Peter A. Glicklich)

  01/01/1988
• Source and Certain Other Jurisdictional Limitations in Light of the Tax Reform Act of 1986, Tax Review

  05/01/1987
• Source of Income From Sales of Personal Property, 35 Can. Tax Journal, 473 (co-authored with Marlene F. Schwartz)

  03/01/1987
• New Regime of Branch Level Taxation Now Imposed on Certain Foreign Corporations, 66 J. Taxation, No. 1, 2

  01/03/1987
• Losses and the Partner: Toward a Rational Basis Standard, 3 Journal of Partnership Taxation 195 (co-authored with Kenneth H. Heitner)

  09/01/1986
• New Statutory Definition of Resident Alien under the Tax Reform Act of 1986, 44 NYU Inst. on Fed. Tax, 46

  01/01/1986
• DRA's Elimination of Withholding Tax on Portfolio Interest, 65 J. Taxation No. 3, 170 (co-authored with Richard G. Fishman)

  01/05/1985
• Revenue Rulings 84-152 and 84-153: Treaty Shopping- Let the Buyer Beware, 33 Can. Tax Journal, No. 1, 158 (co-authored with Kenneth R. Silbergleit)

  01/03/1985
• Broad FIRPTA Withholding Rules are Bound to Affect Canadians, 33 Can. Tax Journal, No. 1, 170-88 (co-authored with Peter A. Glicklich)

  01/01/1985
• Has the 30 Per Cent. Tax on Portfolio Interest Been Eliminated? The British Tax Review, 1985 No. 4 (co-authored with Richard G. Fishman)

  01/01/1985
• Onerous FIRPTA Reporting Requirements Replaced by New Broad Withholding Rules, 61 J. Taxation No. 5, 298 (co-authored with Peter A. Glicklich)

  11/01/1984
• U.S. Taxation of OID Income to Foreign Persons After the 1984 Tax Reform Act, Tax Notes (co-authored with Frank M. Cappuccio)

  09/10/1984
• Proposal Before Congress to Define U.S. Resident Status, 31 Can. Tax Journal No. 5, 853 (co-authored with Herbert H. Alpert with assistance from J. Ross McDonald)

  09/01/1984
• FIRPTA — An Overview of the New Proposed Regulations, 32 Can. Tax Journal, No. 1, 147

  02/01/1984
• An Analysis of the New Law's Tests for an Alien's Status as a U.S. Resident, 61 J. Taxation, No. 4, 228

  01/01/1984
• Proposal Before Congress to Define U.S. Resident Status, Canadian Tax Journal, Selected U.S. Tax Developments, Volume 31, Number 5 (co-authored with Fred Feingold with assistance from J. Ross McDonald)

  09/01/1983
• Recent Procedural Changes Relating to Restructuring Holdings in Foreign Corporations May Have Substantive Significance, 31 Can. J. Taxation, No. 3, 469 (co-authored with Richard G. Fishman)

  05/01/1983
• The Viability of the Personal Service Corporation- the Tax Court is Once Again Heard From, 30 Can. Tax Journal, No. 1, 107-12

  01/01/1982
• The Coordination Between the New Canada-U.S. Treaty and the U.S. Foreign Investment in Real Property Tax Act, Canadian Tax Journal, Selected U.S. Tax Developments

  07/01/1981
• U.S.A.: Foreign Investment in Real Property Tax Act 1980, Bulletin for International Fiscal Documentation, Vol. 35, 1981, No. 5 (co-authored with Fred Feingold)

  05/01/1981
• Observations on the Foreign Investment in Real Property Tax Act of 1980, Virginia Tax Review, Volume 1, Number 1 (co-authored with Fred Feingold)

  03/01/1981
• The Source of a Guarantor's Income, 29 Can. Tax Journal, No. 6, 233-37

  01/02/1981
• Observations on the Foreign Investment in Real Property Tax Act of 1980, 1 Va. Law Review, No. 1, 105 (co-authored with Herbert H. Alpert)

  01/01/1981
• The Use of Substantial Equipment or Machinery at Any Time During the Year as a Permanent Establishment, 28 Can. Tax Journal, No. 2, 222

  01/01/1980

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