Vol. 25 No. 3 - Spring 2006

From the Chair

Taxation

From the Chair

Dennis B. Drapkin

With all the recent focus on the development and implementation of the final Circular 230 written tax advice rules, it is important to remember that Circular 230 imposes other ethical obligations on practitioners. Based on recommendations from former Section chair Dick Lipton, Council has approved creating a task force...

Nominating Committee

Taxation

Nominating Committee Report

ABA Section of Taxation

In accordance with sections 6.1 and 6.3 of the Section of Taxation Bylaws, the following nominations have been submitted by the Nominating Committee for terms beginning at the conclusion of the 2006 Annual Meeting in August. ...

Interview

Taxation

Millie Seidman

Jasper L. Cummings, Jr. and Alan J.J. Swirski

Millie Seidman recently retired from the Tax Division of the U.S. Department of Justice after serving the Division with distinction for 50 years. Since 1985 Ms. Seidman had been the Chief of the Tax Division’s Court of Federal Claims Section, where she supervised and coordinated litigation of large-dollar cases...

Point & Counterpoint

Taxation

Consumption Versus Income Tax

Jasper L. Cummings, Jr.

The term “tax reform” has many meanings. Depending on one’s viewpoint, it might imply simplification, rate reduction, or eliminating the double tax on corporate income. The President’s Advisory Panel on Federal Tax Reform proposed changes to make the “code simpler, fairer, and more conducive to economic growth.” ...

Challenge Point

Taxation

Surveying the Shoals: Tax Hazards Lurk Offshore

Thomas D. Greenaway

Interesting and complex tax issues arise when a U.S. corporation transfers existing patents to—and develops new patents in—a foreign entity. While transferring patents or other intangible property offshore may be a straightforward business decision, especially for a U.S. corporation regularly engaged in worldwide markets...

Points to Remember

Taxation

When Does the Taxpayer Have a Right to an IRS Appeal?

Leandra Lederman and Stephen Mazza

The Internal Revenue Manual provides that “[t]he Appeals mission is to resolve tax controversies, without litigation, on a basis which is fair and impartial to both the Government and the taxpayer and in a manner that will enhance voluntary compliance and public confidence in the integrity and efficiency of the Service.” ...

Taxation

Limited Relief from Over-withholding for Partnerships and Their Foreign Partners: New Section 1446 Regulations

Nancy Beckner

A previous Point that appeared in the Fall 2003 issue of this NewsQuarterly briefly described section 1446 withholding and what were then newly proposed section 1446 withholding regulations (the “2003 Proposed Regulations”), as part of a broader discussion of the use of partnerships by inbound foreign investors. Treasury has now published final section 1446 regulations...

Taxation

Navigating Severance Arrangements in the Section 409 A Sea Change

Frank Tripodi

Section 409A of the Internal Revenue Code (the “Code”), and the subsequently issued proposed regulations, 70 Fed. Reg. 57930 (Oct. 4, 2005), establish an entirely new regime to address the operation of nonqualified plans that provide for the deferral of compensation. Previous Points in this NewsQuarterly have discussed various aspects of the changes...

Pro Bono Award

Taxation

2006 Pro Bono Award Recipient: Janet Spragens

Leslie Book

It is truly an honor for me to stand here today to accept the Tax Section’s pro bono award on behalf of my friend and colleague, Janet Spragens. Janet is a pioneer; she is a woman whose work touches and will continue to touch thousands of people in ways that are both far-reaching and immediate. Janet is the rare academic who not only criticizes, but who offers solutions. ...

Spotlight on Committees

Taxation

Diversity

Walter W. Burford

This is an exciting time for the Diversity Committee. As a result of our newly customized Committee strategy, the efforts of the Committee’s leadership team, and the partnerships we have undertaken within and outside of the Section, we have increased our membership by more than 40% in the first six months of this fiscal year. ...

News Briefs

Taxation

News Briefs

ABA Section of Taxation

Tax Section news and announcements.

Law Student Tax Challenge

Taxation

2005 Law Student Tax Challenge Winners

ABA Section of Taxation

The Section is pleased to announce the winners of the 2005 Law Student Tax Challenge.

Boxscore

Taxation

Government Submissions Boxscore

ABA Section of Taxation

Since February 2006, the Section has coordinated the following government submissions, which can be viewed and downloaded free of charge from the Section’s website.

Renew Your ABA Membership

Vol. 25 No. 3 - Spring 2006

NewsQuarterly, Vol. 25 No. 3

From the Chair

From the Chair

Nominating Committee

Nominating Committee Report

Interview

Millie Seidman

Point & Counterpoint

Consumption Versus Income Tax

Challenge Point

Surveying the Shoals: Tax Hazards Lurk Offshore

Points to Remember

When Does the Taxpayer Have a Right to an IRS Appeal?

Limited Relief from Over-withholding for Partnerships and Their Foreign Partners: New Section 1446 Regulations

Navigating Severance Arrangements in the Section 409 A Sea Change

Pro Bono Award

2006 Pro Bono Award Recipient: Janet Spragens

Spotlight on Committees

Diversity

News Briefs

News Briefs

Law Student Tax Challenge

2005 Law Student Tax Challenge Winners

Boxscore

Government Submissions Boxscore

ABA Resources

The ABA

Connect

Renew Your ABA Membership

American Bar Association TM American Bar Association

Vol. 25 No. 3 - Spring 2006

NewsQuarterly, Vol. 25 No. 3

From the Chair

From the Chair

Nominating Committee

Nominating Committee Report

Interview

Millie Seidman

Point & Counterpoint

Consumption Versus Income Tax

Challenge Point

Surveying the Shoals: Tax Hazards Lurk Offshore

Points to Remember

When Does the Taxpayer Have a Right to an IRS Appeal?

Limited Relief from Over-withholding for Partnerships and Their Foreign Partners: New Section 1446 Regulations

Navigating Severance Arrangements in the Section 409 A Sea Change

Pro Bono Award

2006 Pro Bono Award Recipient: Janet Spragens

Spotlight on Committees

Diversity

News Briefs

News Briefs

Law Student Tax Challenge

2005 Law Student Tax Challenge Winners

Boxscore

Government Submissions Boxscore

ABA Resources

The ABA

Connect