Publications of Interest > Tax > Business & Finance > Practices : Morgan, Lewis & Bockius

11/24/08 Tax Considerations for Participants in U.S. Treasury’s Capital Purchase Program

LawFlash/Client Alert | Financial Crisis Impact and Analysis Alert
Tax Practice

Recent financial reports suggest that as many as 40% of the institutions in the banking and thrift industry will eventually participate in the U.S. Treasury Department’s $250 billion Capital Purchase Program (CPP).more

10/08/08 Certain Tax Provisions of the Emergency Economic Stabilization Act of 2008 and IRS Guidance Relating to the Economic Crisis

LawFlash/Client Alert | Financial Crisis Impact and Analysis Alert
Tax Practice

H.R. 1424 (the Act), which was signed into law by President Bush on October 3, 2008, contains tax-related provisions that can have significant implications for financial institutions, certain hedge funds, and investment... more

10/06/08 International Tax: U.S. Legislative Update

LawFlash/Client Alert | Financial Crisis Impact and Analysis Alert
Tax Practice

A number of important provisions impacting international transactions are included in H.R. 1424 (the Bill), which President Bush signed into law on October 3, 2008. The Bill was approved by the Senate on Octobe... more

10/05/08 The Emergency Economic Stabilization Act of 2008: Impact of the Historic New Law

LawFlash/Client Alert | Financial Crisis Impact and Analysis Alert
Business and Finance Practice

The Emergency Economic Stabilization Act of 2008 (the “Act”) was signed into law by President Bush on October 3, 2008. Passage of the Act was the result of intense debate in both the U.S. Senate and the U.S. Ho... more

08/20/08 Final Instructions to 2008 Form 990 Unveiled by IRS

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tax-Exempt Organizations Practice

On August 19, the Internal Revenue Service (IRS) released final instructions to the redesigned Form 990, the information return filed by public charities and other tax-exempt organizations. The final instructio... more

04/09/08 IRS Releases Long-Awaited Instructions to Revised 2008 Form 990

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tax-Exempt Organizations

On April 7, the Internal Revenue Service (IRS) released draft instructions to the redesigned Form 990, the information return filed by public charities and other tax-exempt organizations. The redesigned Form 99... more

01/30/08 Critical Tax Issues for IP Managers, Palo Alto

Presentation | Speech
William Colgin, Jr.

12/21/07 IRS Releases Revised 2008 Form 990

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tax-Exempt Organizations

On December 20, the IRS released a revised version of the Form 990, the information return filed by public charities and other tax-exempt organizations, which will be required for the 2008 tax year (returns fil... more

10/22/07 Panel on the Nonprofit Sector Issues Final Report on Best Governance Practices

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tax-Exempt Organizations

The Panel on the Nonprofit Sector (the Panel) recently released Principles for Good Governance and Ethical Practice: A Guide for Charities and Foundations (the Guide ), the culmination of a process to i... more

07/31/07 Office of Foreign Assets Control Reviews Activities of Nonprofit Organizations in Sanctioned Countries

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tax-Exempt Organizations

Nonprofit organizations that engage in international activities need to understand the role of the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) in administering and enforcing U.S. embargoes that... more

07/26/07 Release of IRS Letter on Compliance Issues within the Tax-Exempt Sector and Oversight Subcommittee Hearing on Charitable Organizations

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tax-Exempt Organizations

Congressional interest in the tax-exempt sector remains strong. On July 24, Sen. Charles Grassley, Ranking Member, Committee on Finance, released a 28-page letter from the Internal Revenue Service (IRS) identif... more

06/18/07 IRS Releases Dramatically Redesigned Form 990 for Public Comment

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tax-Exempt Organizations

On June 14, the IRS released a substantially revised draft Form 990, Return for Exempt Organizations, which will likely be the basis for the Form 990 used by organizations beginning with the 2008 tax year (that is, for ... more

05/30/07 Second Circuit Rules District Court Lacked Jurisdiction to Order KPMG to Stand Trial for Its Failure to Pay Defendants’ Legal Fees

LawFlash/Client Alert | Litigation LawFlash
Litigation

The U.S. Court of Appeals for the Second Circuit in New York held on May 23, 2007 that District Judge Lewis Kaplan lacked jurisdiction to open a separate civil proceeding to resolve an attorney fee dispute between KPMG LLP and former partners and employees charged with the sale of allegedly improper tax shelters.

05/17/07 IRS Releases Guidance on Public Disclosure of Form 990-T

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tax-Exempt Organizations

On May 9, the IRS issued Notice 2007-45, which provides interim guidance on the new Form 990-T public disclosure requirement enacted as part of the Pension Protection Act of 2006 (PPA). Pursuant to the PPA, For... more

05/07/07 IRS Releases Clarifying Guidance on Completing the 2006 Form 990

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tax-Exempt Organizations

On April 26, 2007, the IRS released supplemental guidance on several issues with respect to the 2006 Form 990. The new guidance, which is presented in a Q&A format, is posted on the IRS website and addresse... more

04/27/07 IRS Expands Scrutiny of Businesses Making Payments to Nonresident Aliens and Foreign Entities

LawFlash/Client Alert | Tax LawFlash
Tax

Officials from the Internal Revenue Service (IRS) have disclosed that the IRS is expanding the scope of its withholding and reporting agent compliance initiative beyond the financial services industry and will soon target nu... more

April 2007 Brands in the Boardroom 2007: Optimising Brand Value Through Strategic Tax Planning, Supplement to IAM Magazine

Outside Publications | Article
Karen Butcher, William Colgin, Jr.

Spring 2007 Relief from Gift Restrictions: Cy Pres and Deviation, Art Law Clinic Newsletter, Vol. 2, No. 1

Outside Publications | Article
Frances Babb

03/15/07 Who Can Sue the Museum: The Evolving Doctrine of Legal Standing, presented at the ALI-ABA Legal Issues in Museum Administration, Philadelphia

Presentation | Speech
Frances Babb

03/01/07 IRS Releases Executive Compensation Report and Nonprofit Panel Requests Public Comment on Self-Governing Principles

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tax-Exempt Organizations

Today, the IRS released a report describing the results of its Exempt Organizations Executive Compensation Compliance Project. According to the report, a significant portion of the organizations contacted had provid... more

02/14/07 IRS Provides Interim Guidance on New Tax Shelter Rules for Exempt Organizations

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tax-Exempt Organizations

On February 7, the IRS released Notice 2007-18, providing interim guidance on the scope of new tax shelter reporting and penalty rules enacted by the Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA). TIPRA crea... more

02/07/07 IRS Continues Focus on the Governance Practices of Charities and Requests Comments on Donor-Advised Funds and Supporting Organizations

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tax-Exempt Organizations

The IRS has joined the public debate regarding the specific governance practices of charitable organizations with the release on February 2, 2007 of its paper titled “Good Governance Practices For 501(c)(3) Organizations.”more

12/21/06 Update on IRS Guidance for Exempt Organizations Affected by the Pension Protection Act of 2006

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tax-Exempt Organizations

On August 17, 2006, President Bush signed into law the Pension Protection Act of 2006 (PPA), which included several charitable giving incentives and numerous reforms primarily affecting charitable organizations and their don... more

10/24/06 Best Practices for Financial Management in Nonprofit, Washington, D.C.

Presentation | Speech
Tomer Inbar

09/12/06 New Tax Shelter Reporting Requirements and Penalties Enacted by Congress

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Gary Wilcox, William Zimmerman, Tomer Inbar, Ann Batlle, Drew Porter, Celia Roady

The Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA), enacted earlier this year, may expose tax-exempt entities and their managers—potentially including outside investment managers—to significant new penalties ... more

08/11/06 Pension Protection Act of 2006 Includes Numerous Charitable Provisions

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tax-Exempt Organizations

On August 3, 2006, the Senate joined the House of Representatives in passing the Pension Protection Act of 2006 (PPA), which includes many provisions intended to stimulate charitable giving and to discourage perceived tax la... more

08/08/06 Recent FASB Release Addressing the Accounting Treatment of Uncertain Income Tax Positions Is Likely to Increase the Need for Tax Opinions Supporting Such Positions

LawFlash/Client Alert | Tax LawFlash
Tax

The recent release of FASB Interpretation No. 48, Accounting for Uncertainty in Income Taxes (FIN 48), is likely to result in increased requests by accountants and enterprises preparing financial statements for legal opinion... more

August 2006 IRS Holds Rental of Hotel-Type Facilities to Prospective Students, Families and Other Campus Visitors to be Substantially Related to Theological School’s Exempt Purposes, The Exempt Organization Tax Review

Outside Publications | Article
Kimberly Eney

07/19/06 Coltec Industries, Inc. v. United States: Significant Win for United States in Tax Shelter Case Reemphasizes Importance of Careful Tax Planning in Complex Business Transactions

LawFlash/Client Alert | Tax LawFlash
Tax

In a much-anticipated tax shelter–related decision, the Court of Appeals for the Federal Circuit, on July 12, 2006, reversed a taxpayer victory in the Court of Federal Claims holding that the economic substance doctrine does... more

05/31/06 Charities in Delaware, presented before The Tax-Exempt Organizations in Delaware Seminar, Newark, NJ

Presentation | Speech
Tomer Inbar

05/18/06 International Grantmaking, presented at the 34th Annual Tax Seminar on Private Foundations, Salk Institute, Carlsbad, CA

Presentation | Speech
Celia Roady

05/17/06 What Foundation Managers Need to Know About the Qualifying Distribution Rules, presented at the 34th Annual Tax Seminar on Private Foundations, Salk Institute, Carlsbad, CA

Presentation | Speech
Celia Roady

04/27/06 Charities and Economic Development, presented at the Georgetown University Law Center, Washington, D.C.

Presentation | Speech
Tomer Inbar

04/12/06 California Protective Claim for Refund of Annual LLC Fee

LawFlash/Client Alert | Tax LawFlash
Tax

In a recent California Superior Court case, Northwest Energetic Services, LLC v. California Franchise Tax Board (Cal. Super. Ct. No. CGC -05-437721? Mar. 3, 2006), the court held that the annual California fee based o... more

04/07/06 Elephants and Donkeys on Campus: Political Campaigns and Colleges and Universities, presented at the National Association of College and Business Attorneys, Washington, D.C.

Presentation | Speech
Celia Roady

12/08/05 Treasury Department Issues Revised Anti-Terrorist Financing Guidelines Applicable to Both Foreign and Domestic Grants

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Celia Roady

On Monday, December 5, 2005, the Treasury Department issued revised Anti-Terrorist Financing Guidelines: Voluntary Best Practices for U.S.-Based Charities. The revised Guidelines replace the Guidelines issued b... more

11/19/05 Senate Passes Tax Legislation with Significant Exempt Organization Reforms, Anti-Abuse Rules and Charitable Giving Incentives

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tomer Inbar, Ann Batlle, Drew Porter, Celia Roady

On November 18, 2005, the Senate passed the Tax Relief Act of 2005 (S. 2020), which contains several significant modifications to the tax rules governing exempt organizations and charitable giving. The companio... more

15 novembre 2005 International Tax Systems - France, International Tax Systems and Planning Techniques (ITSAPT), Roy Saunders, éditeur: Thomson/Sweet & Maxwell. Ce chapitre dédié à la France est écrit par Patrice Lefèvre Péaron; il a été mis à jour en mars 2006. Attention ce document faisant 84 pages, seule l'introduction figure sur notre site (2 pages).

Outside Publications | Chapter
Patrice Lefèvre-Péaron

10/28/05 IRS Announces Limited-Time Settlement Initiative for Certain "Abusive" Transactions

LawFlash/Client Alert | Tax LawFlash
Tax

On October 27, the Internal Revenue Service (IRS) announced a short-term settlement initiative for taxpayers involved in a broad array of transactions that the IRS deems abusive. Eligible participants in the in... more

Fall 2005 Charitable Giving Focus: In-Kind Gifts, Art Law Clinic Newsletter, Vol. 1, No. 1

Outside Publications | Article
Frances Babb

09/23/05 Hurricane Katrina Tax-Relief Legislation and Senate Finance Subcommittee Hearing on "Charities on the Frontline: How the Nonprofit Sector Meets the Needs of America's Communities"

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tomer Inbar, Ann Batlle, Celia Roady

There has been some significant activity in Congress over the past couple of weeks on tax issues affecting the charitable sector. On September 21, 2005, Congress enacted temporary tax relief legislation related... more

4 juillet 2005 Cession de contrat de crédit-bail immobilier, Option Finance, n° 841

Outside Publications | Article
Patrice Lefèvre-Péaron

06/15/05 Internal Revenue Service Circular 230: Implications for Tax Advice Provided by Morgan Lewis

White Paper | Morgan Lewis White Paper
Christina Harper, Kenneth Kail

The U.S. Treasury and the Internal Revenue Service recently published regulations governing practice before the Internal Revenue Service, which are effective for written U.S. federal tax advice provided after June 20, 2005.<... more

06/08/05 State Legislative Developments Affecting Charitable Organizations

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tomer Inbar, Ann Batlle, Celia Roady

The attorneys general in certain states – including New York and Massachusetts – have begun to focus increased scrutiny on the corporate governance and fundraising practices of non-profit organizations, in line with sim... more

30 mai 2005 La directive «fusions» inapplicable aux opérations purement françaises? Une résistance malvenue, Option Finance, n° 836

Outside Publications | Article
Patrice Lefèvre-Péaron

05/24/05 United States Supreme Court Holds that Criminal Wire Fraud Statute Encompasses Schemes to Violate Foreign Law

LawFlash/Client Alert | Litigation LawFlash
Miriam Fisher, John Hemann

On April 26, 2005, the United States Supreme Court upheld criminal convictions arising from a scheme to avoid taxation by a foreign government. The decision in Pasquantino v. United States , 125 S. Ct. ... more

15 mai - 15 juin 2005 Plans d'attribution gratuite d'actions et de stock-options: quelle cohabitation? Décideurs: Stratégie, Finance & Droit, n° 65

Outside Publications | Article
Anne Tolila, Patrice Lefèvre-Péaron

05/03/05 To Tax or Not to Tax - UBIT Rules for Museums; presented before American Association of Museums, Indianapolis

Presentation | Speech
Ann Batlle

04/27/05 IRS Forms and Filing Requirements - Georgetown University Law Center's conference on "Representing and Managing Tax-Exempt Organizations," Washington, D.C.

Presentation | Speech
Ann Batlle

March 2005 Lease Strips and Viral Stock: Are They Dead Yet?

White Paper | Morgan Lewis White Paper
Gary Wilcox

This White Paper explores some of the implications of the Long Term Capital Holdings decision. It covers the analysis of not only lease strips and their progeny, known as “viral stock,” but also other sh... more

March 2005 Long Term Capital Holdings v. United States: The End of Penalty Protection?

White Paper | Morgan Lewis White Paper
Miriam Fisher

The Long Term Capital Holdings decision, issued by the U.S. District Court for the District of Connecticut on August 27, 2004, presents a microscopic case study of the heyday of sophisticated and aggressive tax planni... more

February 2005 Recent Joint Committee on Taxation Proposals Affecting Exempt Organizations

LawFlash/Client Alert | Tax LawFlash
Tomer Inbar, Ann Batlle, Celia Roady

On January 27, the Joint Committee on Taxation (“JCT”) released a 430-page report describing proposals to curtail tax shelters, close loopholes, and address other areas of noncompliance. The report, “Options to... more

01/25/05 Government Issues Vital Guidance on Repatriated Foreign Earnings Tax Break

LawFlash/Client Alert | Tax LawFlash
Tax

One of the most important provisions of the American Jobs Creation Act of 2004 that Congress passed last October is an 85% exclusion for certain dividends received by U.S. corporations from controlled foreign corporatio... more

01/10/05 U.S. Treasury Issues Regulations Affecting Taxes on Cross-Border Mergers

LawFlash/Client Alert | Tax LawFlash
Richard Zarin

Last week, the U.S. Treasury issued proposed regulations that for the first time would allow tax-free treatment for cross-border mergers organized under foreign law. These regulations, if adopted, will put non-... more

June/July 2004 IRS Audits of Tax Exempt Organizations: Understanding and Preparing for an Examination, Journal of Tax Practices and Procedures

Outside Publications | Article
Ann Batlle

06/10/03 President Bush's $350 Billion Tax Cut: Analysis and Impact

LawFlash/Client Alert | Tax LawFlash
Tax

On May 28, 2003, President Bush signed into law the Jobs and Growth Tax Relief Reconciliation Act of 2003 (the “Act”). The Act incorporates many of President Bush’s original proposals set forth in the FY 2004 B... more

02/10/03 Treasury Description of the President's Dividend Exclusion Proposal

LawFlash/Client Alert | Tax LawFlash
Tax

This Lawflash summarizes the description of President Bush’s dividend exclusion proposal (the “Proposal”) released by the Treasury Department on January 21, 2003 (the “Treasury Description”) and modified in materials re... more

11/02/01 Corporate Sponsorships: Proposed Regulations Offer New Guidance, presented at the Western Conference on Tax-Exempt Organizations, Los Angeles

Presentation | Speech
Celia Roady

November 2001 Morgan Lewis on Global Tax Issues
November 2001

Newsletter | Morgan Lewis on Global Tax Issues
Tax

In this Issue:

Economic Downturn Provides Window of Opportunity: Now is the Time for Restructuring Euro... more

August 2001 Final Federal Regulations Governing the Confidentiality and Privacy of Health Information

White Paper | Morgan Lewis White Paper
Tax

More than a year after the Department of Health and Human Services (“HHS”) issued proposed regulations, mandated by Congress under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), HHS issued final r... more

January 2001 Personal Injury Liability of Owners and Occupiers For Construction-Related Asbestos Exposure in New York, Mealey's Litigation Report: Asbestos

Outside Publications | Article
Bernard Garbutt III

09/21/00 UBIT Problems for Tax-Exempt Charitable Trusts: 35th Southern Federal Tax Institute, Atlanta, GA

Presentation | Speech
Celia Roady

09/15/00 Finding a Friend in the Frenzy - Joint Ventures for Long-and Short-Term Growth Plans, presented at the Strategic Research Institute, New York

Presentation | Speech
Richard Zarin

06/14/00 Inbound Grantor Trusts, presented at the Practising Law Institute, New York

Presentation | Speech
Ellen K. Harrison

June 2000 Current U.S. Expatriation Issues Affect Employees on Long-term Assignments to the U.S. or Abroad, The In-House Lawyer

Outside Publications | Article
Joan Ingram

03/15/00 Constitutional Issues in State Taxation of Trusts, presented to the District of Columbia Bar, Washington, D.C.

Presentation | Speech
Ellen K. Harrison

03/01/00 Hospital/Physician Gainsharing Arrangements: Dead or Alive?, Presented at the PBI Sixth Annual Health Law Institute, Philadelphia

Presentation | Speech
John R. Washlick, John A. Knapp of Cozen and O'Connor

03/01/00 Part II: Factors Relevant to Choosing the Best Split Interest Technique, presented at the 2000 ACTEC Annual Meeting, Scottsdale, AZ

Presentation | Speech
Ellen K. Harrison

December 1999 New Federal Regulations Governing the Confidentiality of the Electronic Transmission of Medical Records

White Paper | Morgan Lewis White Paper
John Bales, III

On November 26, 1999, the National Labor Relations Board (NLRB) held that house staff, composed of interns, residents and fellows, are employees subject to the National Labor Relations Act (NLRA). The decision ... more

11/01/99 Federal Tax Limitations on Lobbying and Political Activities by Section 501(c) (3) Organizations, presented at the ALI-ABA Course of Study Tax-Exempt Charitable Organizations, Washington, D.C.

Presentation | Speech
Celia Roady

10/15/99 Income and Estate Planning Opportunities Upon the Sale of a Closely Held Business, presented to the District of Columbia Bar, Washington, D.C.

Presentation | Speech
Ellen K. Harrison

07/01/99 Intentionally "Defective" Grantor Trusts, presented to the Tax Study Group, Montgomery/Prince George's County, MD

Presentation | Speech
Steven Stone

06/01/99 Foreign Aspects of Charitable Remainder Trusts, presented at the 1999 Estate Planners Day, New York

Presentation | Speech
Ellen K. Harrison

June 1999 The European Community Data Protection Directive

White Paper | Morgan Lewis White Paper
Business and Finance

On October 25, 1998, the European Community (the “EC”) adopted a Directive (the “Directive”) “on the protection of individuals with regard to the processing of personal data and on the free movement of such data.” The Di... more

04/15/99 U.S. Cross-Border Leasing Structures at (Almost) the Millennium, presented at the FDTA's 10th Annual U.S. Cross-Border Leasing Conference, New York

Presentation | Speech
William A. Macan IV, David K. Burton

April 1999 European Union, Mergers & Acquisitions Yearbook 1999, International Financial Law Review Supplement

Outside Publications | Article
Izzet Sinan

01/01/99 The Innocent Spouse Claim: New Rules and Strategies, presented at the 1999 National CLE Conference, Vail, CO

Presentation | Speech
Miriam L. Fisher

12/17/98 Intermediate Sanctions: What You Need to Know, presented at the Exempt Organizations Conference, New York

Presentation | Speech
Celia Roady

December 1998 EASDAQ: The Pan-European Stock Market for Growth Companies

White Paper | Morgan Lewis White Paper
Stephen Goodman

The European Association of Securities Dealers Automated Quotation, or EASDAQ, was officially launched on September 30, 1996. It is a pan-European screen-based stock market inspired by the European Commission’s concern t... more

11/15/98 Exempt Organizations and the Internet: Current Tax Issues (Part II), Association Law & Policy

Outside Publications | Article
Celia Roady

November 1998 Exempt Organizations and the Internet: Current Tax Issues (Part I), Association Law & Policy

Outside Publications | Article
Celia Roady

November 1998 Independent Contractors and the National Labor Relations Act, The Metropolitan Corporate Counsel

Outside Publications | Article
Miriam Fisher

10/29/98 Implications of "The Taxpayer Bill of Rights" and Intermediate Sanctions, presented at the Executive and Physician Compensation in Health Care Systems Seminar, Tarrytown, NY

Presentation | Speech
John R. Washlick

10/29/98 Political Activities of Tax-Exempt Organizations: Federal Income Tax Rules and Restrictions, presented at the National Center on Philanthropy and the Law, New York

Presentation | Speech
Celia Roady

10/02/98 Exempt Organizations and the Internet: Current Tax Issues, presented at the 12th Annual Legal Symposium, Washington, DC

Presentation | Speech
Celia Roady

10/01/98 Intermediate Sanctions Affecting Healthcare Organizations, presented at an in-house healthcare seminar

Presentation | Speech
Stephen Goodman

October 1998 Proposed Regulations for Intermediate Sanctions Rules

White Paper | Morgan Lewis White Paper
Celia Roady

On July 30, 1998, some two years after the enactment of Section 4958, the Internal Revenue Service issued proposed regulations under the “intermediate sanctions” rules that govern transactions between Section 501(c)(3) and (... more

10/01/98 Tax Avoidance: Transfer of Assets Abroad, presented at the Essential Onshore & Offshore Tax Planning for the Wealthy and Their Advisers Seminar, London

Presentation | Speech
David J. Way

08/24/98 Easing the Tax Burden of Working Abroad: Part II; How to Elect the Foreign Earned Income Exclusion, Practical U.S./International Tax Strategies

Outside Publications | Article
Ellen K. Harrison

06/18/98 Intermediate Sanctions and Compensation Issues, 6th Annual AICPA Not-for-Profit, Washington, D.C.

Presentation | Speech
Celia Roady

06/01/98 U.S. Tax Law Changes Affecting International Personal Tax Planning, presented to the Institute for Private Investors, London

Presentation | Speech
Ellen K. Harrison

05/21/98 Overview of U.S. Law Issues in Relation to the Introduction of the Euro, presented at The Euro Capital Markets Summit

Presentation | Speech
Howard M. Liebman

05/21/98 U.S. Federal Income Tax Consequences and Deductibility of Costs, presented at the Euro Capital Markets Summit

Presentation | Speech
Howard M. Liebman

05/01/98 1998 Employee Benefits Case Law Update, presented at the Employee Benefits and Executive Compensation Seminar, Philadelphia

Presentation | Speech
Allison E. Wielobob, Joshua Pepper

04/24/98 Understanding UBIT: A Primer, presented at the 15th Annual Representing & Managing Tax-Exempt Organizations, Washington, D.C.

Presentation | Speech
Celia Roady

04/17/98 The Pickle Service Contract Structure, presented at the FDTA's 9th Annual U.S. Cross-Border Leasing Conference, New York

Presentation | Speech
William A. Macan IV

04/16/98 A Comparison of Retained Annuities and Sales to Grantor Trusts, presented to the Advanced Estate Planning Institute, Baltimore

Presentation | Speech
Ellen K. Harrison

04/16/98 Estate Freeze by a Sale to an Intentionally Defective Grantor Trust or a Gift to a Grantor Retained Annuity Trust - Which Is Better? Presented to the New Jersey Federal Tax Day, New Brunswick, NJ

Presentation | Speech
Ellen K. Harrison

04/01/98 A European Approach to Transfer Pricing: Five Selected Countries, presented at the Transfer Pricing Seminar, Brussels, Belgium

Presentation | Speech
Howard M. Liebman

April 1998 European Union: A Special Report, International Financial Law Review

Outside Publications | Article
Izzet Sinan

04/01/98 Legal Outline - Burden of Proof in the Tax Court, presented at Georgetown University Law Center CLE Program, Washington, D.C.

Presentation | Speech
Miriam L. Fisher

04/01/98 The New Frontier of Physician Practice Management Companies: Publicly Traded PPMCs, presented at the Pennsylvania Bar Institute's 4th Annual Health Law Institute, Philadelphia

Presentation | Speech
John R. Washlick, John A. Knapp of Omnia, Inc.

04/01/98 U.S. Transfer Pricing Issues of Concern to Foreign Persons Investing or Doing Business in the U.S., presented at the Transfer Pricing Seminar, Brussels

Presentation | Speech
Howard M. Liebman

02/26/98 Solving International Tax Problems for the Estate Planner - Planning for Foreign Employment, presented at the 1998 ACTEC Annual Meeting, Orlando, FL

Presentation | Speech
Ellen K. Harrison

02/12/98 Deferred Annuities, presented at the 11th ABA Annual Conference on Electricity Law and Regulation, Denver, CO

Presentation | Speech
Ellen K. Harrison

02/01/98 Recent Developments in UK Taxation of Offshore Trusts, presented to the World Offshore Convention 1998, Trust Developments in the Global Marketplace for the International Practitioner, Dublin, Ireland

Presentation | Speech
David Way

01/22/98 Recent Leasing-Related Tax Law Developments, presented at the D'Accord Winter Finance Conference, Telluride, CO

Presentation | Speech
William A. Macan IV

1998 Compliance and Tax Litigation, The Taxpayer Relief Act of 1997, American Bar Association Section of Taxation and the American Law Institute-American Bar Association Committee on Continuing Professional Education: The Taxpayer Relief Act of 1997: American Bar Association Section of Taxation and the American Law Institute-American Bar Association Committee on Continuing Professional Education

Outside Publications | Chapter
Miriam Fisher

01/01/98 Corporate Sponsorship: Recent Legislation Provides New Rules for Exempt Organizations, presented to the Tax Management Advisory Board Meeting, New York

Presentation | Speech
Celia Roady

January 1998 The Sixth Circuit Allows Employer to Modify Retiree Health Benefits

White Paper | Morgan Lewis White Paper
Harry Burton

The U.S. Court of Appeals for the Sixth Circuit has long been considered the court of choice for plaintiff retirees seeking health benefits. This trend seems to be changing, however, as the court moves away fro... more

12/01/97 The Taxation of International Income in Developing Countries, presented at the United Nations Ad Hoc Group of Experts on International Cooperation in Tax Matters 7th Meeting, Geneva, Switzerland

Presentation | Speech
Richard J. Gagnon, Jr.

Winter 1997 UBIT Issues for Colleges and Universities, Educational Record

Outside Publications | Article
Celia Roady

11/20/97 Current UBIT Developments, presented at the Twelfth Annual Tax-exempt Charitable Organizations Conference, Washington, D.C.

Presentation | Speech
Celia Roady

11/13/97 Intermediate Sanctions: A New Weapon Against Tax-Exempt Compensation Abuse, presented at the Western Conference on Tax-exempt Organizations, Los Angeles

Presentation | Speech
Celia Roady

11/12/97 U.S. Tax Leasing - Any Certainty? Presented at The 12th Annual Airfinance Legal Conference, Washington, D.C.

Presentation | Speech
William A. Macan IV

11/01/97 Changes in Post-Mortem Income Tax Planning Under the Taxpayer Relief Act of 1997, presented to The American Bar Association Section of Real Property, Probate and Trust Law and the Center for Continuing Legal Education

Presentation | Speech
Ellen K. Harrison, Ellen L. van Hoften of Cowley & Chidester

11/01/97 Employee or Independent Contractor? Questions of Contingent Worker Classification - Avoiding the Microsoft Result and Other Pitfalls, presented at a ML&B Seminar, Washington, D.C.

Presentation | Speech
Robert Smith

10/28/97 Mergers, Acquisitions and Joint Ventures with Exempt and For-Profit Participants, presented at the Philadelphia Tax Conference, Philadelphia

Presentation | Speech
John R. Washlick

10/01/97 Formation and Operation of Physician Practice Management Companies, presented at The 2nd Annual Health Services Conference, Moon Township, PA

Presentation | Speech
John R. Washlick

10/01/97 Guiding and Controlling Executors and Trustees, presented at the Tax Planning Through Trusts and Wills Seminar, London

Presentation | Speech
David John Way

10/01/97 Outline of Key Considerations to Be Taken into Account in the Introduction of the Euro

White Paper | Morgan Lewis White Paper
Howard M. Liebman

Commercial Changes--Must a company's price lists, catalogues, contracts, and invoices (as well as relating billing procedures) be changed to denominate all currencies in Euros? And if so, as of when?

N... more

09/03/97 New Developments Concerning Charitable Remainder Trusts, presented at the Mass Mutual Agents Meeting, Arlington, VA

Presentation | Speech
Ellen K. Harrison

08/26/97 Income Tax Planning for Inbound Transactions, presented to the Georgetown University Continuing Legal Education Program, Washington, D.C.

Presentation | Speech
Ellen K. Harrison

07/01/97 Ninth Circuit Affirms Decision Requiring Microsoft to Allow Workers Misclassified as Independent Contractors to Participate in Retirement Plans

White Paper | Morgan Lewis White Paper
Michael J. Collins, Brian Dougherty

The Ninth Circuit Court of Appeals, sitting en banc , recently affirmed in most respects, but also modified in one important respect, an earlier decision by a three-... more

06/19/97 Putting Your Royalties at Risk, presented at the Non-Dues Revenue Symposium, American Society of Association Executives, Washington, D.C.

Presentation | Speech
Celia Roady

05/30/97 Update On Nonprofit Housing Corporations: Achieving Tax-Exempt Status, presented at the American Bar Association's 6th Annual Conference on Affordable Housing and Community Development Law, Washington, D.C.

Presentation | Speech
Celia Roady

05/09/97 1997 Employee Benefits Case Law Update, presented to the Employee Benefits and Executive Compensation Seminar, Philadelphia

Presentation | Speech
Allison E. Wielobob, Joshua Pepper

05/09/97 Intermediate Sanctions for Tax-Exempt Organizations, presented at the Employee Benefits and Executive Compensation Seminar, Philadelphia

Presentation | Speech
Michael J. Collins

04/25/97 U.S. Cross-Border Leasing Structures -- Pickle, FSC, LKX and Leasehold Structures -- A History, presented at The FDTA's Eighth Annual U.S. Cross-Border Tax Leasing Conference, New York

Presentation | Speech
William A. Macan, IV

04/18/97 Recent Developments Involving Exempt Organization Retirement Plans: 14th Annual 'Representing & Managing Tax-Exempt Organizations Conference, Georgetown University Law Center, Washington, D.C.

Presentation | Speech
Gregory Needles

04/14/97 Testimony on the History and Background of Some of the Present IRS Administrative Problems, presented Before the U.S. House of Representatives Committee on Government Reform and Oversight, Washington, D.C.

Presentation | Speech

April 1997 European Union, Mergers & Acquisitions Yearbook 1997, International Financial Law Review

Outside Publications | Article
Izzet Sinan

03/01/97 What Did Renault Do Wrong?

White Paper | Morgan Lewis White Paper
Howard M. Liebman, Philippe Dejonghe

The press has been full of reports on the decision taken by Renault to close its Belgian assembly plant in Vilvoorde, near Brussels, at the end of July, with the loss of 3,100 jobs. The resulting investigations... more

01/29/97 Employee/Independent Contractors -- How to Deal With the IRS, presented at the ML&B Labor and Employment Law Seminar, Los Angeles

Presentation | Speech
Miriam L. Fisher

12/10/96 Employee/Independent Contractors -- How to Deal With the IRS, presented at the 18th Annual Human Resources Institute, Los Angeles

Presentation | Speech
Miriam L. Fisher

12/06/96 Spotlight on Current UBIT Developments, presented at the Eleventh Annual ALI-ABA and ABA Section of Taxation Course of Study, Washington, D.C.

Presentation | Speech
Celia Roady

December 1996 Civil Tax Penalties Failure to File, Failure to Pay and The Estimated Tax Penalties, American Bar Association Handbook

Outside Publications | Chapter
Miriam Fisher

Winter 1996 Intermediate Sanctions: A New IRS Weapon Against Tax-Exempt Compensation Abuse, Benefits Law Journal, Vol. 9, No. 4

Outside Publications | Article
Celia Roady

11/16/96 Cybertax - The Impact of the Internet on International Taxation and Vice Versa, presented at the UCLA Entertainment Finance and Tax Institute, Los Angeles

Presentation | Speech
Michael J.A. Karlin

11/01/96 Formation and Operation of Physician Practice Management Companies, presented at the National Health Lawyers Association Tax Issues For Healthcare Organizations, Orlando, FL

Presentation | Speech
John R. Washlick

11/01/96 Ninth Circuit Requires Microsoft to Allow Workers Misclassified as Independent Contractors to Participate in Retirement Plans

White Paper | Morgan Lewis White Paper
Michael J. Collins

A three-judge panel of the Ninth Circuit Court of Appeals recently held, by a 2-1 vote in Vizcaino v. Microsoft Corporation , 1996 WL 560235 (9th Cir.), that an employer must pay benefits under two employee bene... more

11/01/96 Small Business Job Protection Act of 1996 and Taxpayers Bill of Rights 2: Exempt Organization Provision

White Paper | Morgan Lewis White Paper
Celia Roady

President Clinton recently signed into law two legislative bills that will have a significant impact on tax-exempt organizations. This paper presents the highlights of the Small Business Job Protection Act (the... more

November 1996 Tax Exempt Derivatives

LawFlash/Client Alert | Tax LawFlash
Gary Wilcox

10/31/96 Healthcare Developments, presented at the 1996 Tax Issues in Healthcare Organizations Program, Washington, D.C.

Presentation | Speech
John R. Washlick

10/18/96 Tax, the Elections and Beyond: Reality and Rhetoric Behind the Flatter Tax World Program, presented at American University, Washington, D.C.

Presentation | Speech

09/25/96 Identifying Disqualified Persons: Who is at Risk and When, presented at the Intermediate Sanctions, UBIT and You, The National Chamber Foundation and Tax Analysts conference, Washington, D.C.

Presentation | Speech
Celia Roady

07/08/96 Life Insurance in Estate Planning, presented to the Women and Money Group, Bethesda, MD

Presentation | Speech
Ellen K. Harrison

07/01/96 Environmental Tax Issues Under Major Tax Reform Proposals -- Some Special Tax Incentives and Tax Rules for Certain Environmental Expenditures Under Current Law, presented at the Environmental Taxes Committee of the Tax Section of the ABA, Annual Meeting, Orlando, FL

Presentation | Speech
Ellen K. Harrison

June/July 1996 Interview on Audits of Colleges and Universities, Paul Streckfus' EO Tax Journal, Vol. 1, No. 4

Outside Publications | Article
Celia Roady

06/10/96 Planning With Grantor Trusts, presented at the Estate Planning Committee of the D.C. Bar, Washington, D.C.

Presentation | Speech
Ellen K. Harrison

06/08/96 Current Developments Involving Tax-Exempt Organizations, presented at the University of Virginia's 48th Annual Virginia Conference on Federal Taxation, Charlottesville, VA

Presentation | Speech
Celia Roady

06/03/96 Cybertax - The Impact of the Internet on International Taxation and Vice Versa, presented at the ML&B Mandatory Continuing Legal Education Seminar, Los Angeles

Presentation | Speech
Michael J.A. Karlin

06/01/96 IRS Proposes Comprehensive Revisions of Rules On Withholding on Payments to Foreign Persons

White Paper | Morgan Lewis White Paper
Michael J. A. Karlin, Soo-Jeong Ahn

The Internal Revenue Service recently published a set of proposed regulations that will substantially revise the current rules on withholding of income tax on foreign persons' U.S. source income. These regulati... more

05/20/96 The History of Tax Litigation with Colleges and Universities, presented at the Indiana University's Third 1996 Tax Institute for Colleges and Universities, Bloomington, IN

Presentation | Speech
Celia Roady

05/16/96 Proposed Regulation Regarding Deposit of Employee Contributions, presented at the ML&B Employee Benefits and Executive Compensation Seminar, Philadelphia

Presentation | Speech

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