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Vol. 26 No. 4 - Summer 2007


From the Chair

From the Chair-Elect

Distinguished Service Award


2007 Distinguished Service Award Recipient: Loretta Collins Argrett

The Section of Taxation is pleased to honor Loretta Collins Argrett as our 2007 recipient of the Section’s Distinguished Service Award in recognition of her lifetime achievements and contributions to the Tax Section and to the tax profession. Ms. Argrett stands out not only for her excellence and skills as a practicing tax lawyer and professor, but also as a champion for the highest standards of ethics in the legal profession. ...


Opinion Point

Points to Remember


Final Portfolio Interest Regulations Re: Loans from Partnerships and Trusts and Other Recent Portfolio Interest Developments

Interest from U.S. sources received by a nonresident alien or foreign corporation is generally subject to a flat 30% tax to the extent the interest is not effectively connected with the conduct of a trade or business within the United States; an applicable income tax treaty may reduce or eliminate the 30% tax. Sections 871(a)(1)(A) or 881(a)(1). ...


Independent In-house Tax Professionals Take Note: The IRS Office of Professional Responsibility Can Now Impose Monetary Penalties for Misconduct

On April 24, 2007, the Service released Notice 2007-39, 2007-20 I.R.B. 1243 (May 14, 2007), which provides guidance to the Service’s Office of Professional Responsibility in exercising its authority to impose monetary penalties for practitioner misconduct. This authority is granted by section 822 of the American Jobs Creation Act of 2004...

News Briefs


Tax Bites